ML20072H859
| ML20072H859 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/03/1981 |
| From: | Labelle D BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-03, TASK-07, TASK-1, TASK-11, TASK-3, TASK-7, TASK-GB NUDOCS 8306290782 | |
| Download: ML20072H859 (124) | |
Text
-
129 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK y~h
-x ks_J 8
GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a
{
Plaintiffs, 80'CIV. 1683 (R.O.)
-against-l l
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
Defendants.
i
_x Continued deposition of The Babcock &
I Wilcox Company by DANNY W.
LaBELLE, taken by
(
the Plaintiffs, pursuant to adjournment, at i
the offices of Kaye, Scholer, Fierman, Hays
& Handler, Esqs., 425 Park Avenue, New York, t
New York, on Wednesday, the 3rd day of June.
1981(globb3)
,gcommencing at 9 49 o' clock in the forenoon, before Charles Shapiro, a Certified Shorthand Reporter and Notary Public in and for The State of New York.
B306290782 810603 PDR ADOCK 0500028 i
DOYLE REPORTING. INC.
.O CERTIFIED STEN OTYPE REPORTERS k
369 Lzx NotoN Avtsus
{
New Yom<.
N.Y.
1 Cot?
WALTER SH APIRO, C.S.R.
Tst.z puc N g 212 - S67-8220 CHARLES SH APIRO. CJ.R.
1 130 2
APP e a ra nc e s:
3 4
i KAYE, SCHOLER, FIERMAN,, HAYS & HANDLER, ESQS.
5 Attorneys for Plaintiffs 425 Park Avenue 6
By's STEVEN J.
GLASSMAN, ESQ.,
l 8
of counsel e
f 9
10 DAVIS POLK & WARDWELL, ESQS.
{
Attorneys for Defendants 11 One Chase Manhattan Plaza New York, New York 12 By:
ROBERT F.
- WISE, JR.,
ESQ.
13
-and-WILLIAM E.
WURTZ, ESQ.,
14 of counsel 15 16 17 Also Present:
18 DAVID TAYLOR 19 20 21 22 23 l
24 25
w 1
131 2
D ANNY W.
LLB E 'L L E resumed 0
3 as a witness and, having been previously duly 4
sworn, was examined and tactified further as 5
follows:
\\
6 EXAMINATION (Continrid) 7 BY MR. GLASSMAN:
l l
8 Q
Mr. LaBelle, I would like you to focus 9
again on GPU Exhibit-286 marked for identification.
i Ib The last full paragraph beginning with the words 4
- 1 l{
11 "As Safety Analysis proceeds," contains a reference to h
12 an interface structure.
13 Can you tell us what you had in mind in 14 using those terms?
15 A
The units listed here interface with each other.
i l
16 Q
How was the build-up of an interface
[
17 structure between the various units as reflected in l
18 this memorandum different from the structure as it b
19 existed before that time?
i 20.
A Just in terms of the amount of work activity.
l s
21 Q
The second sentence of that paragraph I
22 says that i
23
"... there is the potential for confusion 24 over work responsibilitie-, cost recovery and i
25 work control."
j h
I.
1 LaBelle.
132 2
Why was there a potential for confusion 3
ver work responsibilities?
4 A
I think the reference is more to awareness by 5
those organizations in their interfacing of the work 6
that was being conducted.
7 Q
Had there been any prior confusion over l
8 work responsibilities?
I 9
A No, sir.
10 Q
That paragraph ends with the sentence:
i 11 "I
therefore request that you please
}
12 review our recommendations...."
13 To what recommendations were you referring Ok,)
14 in that sentence?
15 A
Not having complete recall of the recommendations i
16 that are suggested here, I can only accept what is 17 stated here in the memo,which are the activities that L
18 are prescribed in A, B and C and the attached 19 recommendations of Mr. Vosburgh and Mr. Bonoca.
20 Q
Did you receive directional input from 21 Dr. Roy or Dr. Womack in reLpons2 to your request?
22 A
I have no recollection that that took place.
23 Q
I would like to refer to the next page of f
24 GPU Exhibit-286 marked for id en tifit:a tion, which is page-I (tqcSoD l
first pageAof the May 1, 1979Aattachment from Mr.
(g 25 the
'Q r
f h
k
1 LaBelle 133 T
2 vosburgh and Mr. Bonoca to yourself.
The second full (fGW$0
~
3 paragraph rea s as follows:
4 4
"Our opinion is that the following recommendations are of extreme importance 5
I i
and should receive Enginearing Department 6
7 attention to provide the impetus for their 8
implementation."
9 Did you agree with that recommendation 10 in that statement?
11 A
At the time that this information was forwarded 12 to Dr. Womack and Dr. Roy I had at least in principal
(
13 indicated the importance of the information, not 14 necessarily.the extreme importance of the information.
15 Q
To whom had you indicated the importance 16 of that information?
17 A
Just in the fact that this information was 18 escalated to my. superiors.
19 Q
The next paragraph of the May 1st, 1979A 905o7) 20 attachment to your May 7th, 197 memo refer to as l
21
"... comprehensive safety evaluation of i
22 the 177-FA plants based on event tree 23 evaluations, and not strictly on licensing l
24 requirements."
2' 25 How did such a program differ from what
!O b
1 LaBelle 134 had been done before?
2 fj}@
(O) s/
A The Safety Analysis ReportAcontained licensing 3
4-guidelines provided by the Nuclear Regulatory Nh cmaissio(qgforassumptionsandpresentationofmaterials 5
6 supporting transient and accident sequences.
i l
7 Q
Were event tree evaluations used by q)y)1 (9903AS) 8 Prior to the TMI-2.accideng?
A While I was unit manager of Safety Analysis we 9
did not utilize event tree evaluations.
10 11 Q
'Were event tree evaluations techniques i
12 known to you during the period you were manager of the 13 safety. Analysis Unit and prior to the TMI-2 accident?
()
14 A
Yes, sir.
15 Q
Why were they not used at that time?
16 A
This was not a normal practice within the unit 17 at that time.
18 Q
Why was it not a normal practice within 19 the unit at that time?
20 A
The transient and accident analysis were based l
21 upon licensing guidelines that had previously been 22 established.
J 23 Q
Is there any other reason why event tree 24 evaluations were not used prior to the TMI-2 25 accident?
A b
~
s m..,,
.__,.,m, y_,
~
1 1
LaBalle 135 2
A No, sir.
3 Q
Have event tree evaluations been used by TMI-2 acciden(t?99n3p8) 4 S[M[$ subsequent to the g
i 5
A Yes, sir.
4 6
Q Are event tres evaluations now required
{
7 by NRC licensing guidelines?
8 A
I do not know.
i 9
Q Do you know of.any such licensing l
1 10 guidelines requiring event tree evaluations?
3 11 A
I have no recollection of those, no, sir.
11 I
12 Q
. Wh'y are event tree evaluations now used 13 by,B & W7
()
14 A.
I have no specific recollection as to why they 4
15 are being used presently.
4 16 Q'
What is their function?
4 17 A
To better understand the overall component and i
18 system response.
{
19 Q
Is it correct to say that event tree i
)
20 evaluation now provides a better understanding of i
3 21 system response than existed within B & W prior to the J
F 22 TMI-2 accident?
u A
I could not say with assurety that that is t r u e",
4 24 no, sir.
I 25 Q
Do you have an opinion on the subject?
ii t
7-1 LaBelle 136 O.
2 MR. WISE:
I am going to object to that.
I d n't think his opinions are relevant or 3
5 4
helpful on a question of that nature following the accideng(ynosasO l
$P 5
MR. GLASSMAN:
Mr. LaBelle is director of 6
7 Safety. Analysis or at least was at certain 8
times after the accident and he can answer the 9
question.
i 10 MR. WISE:
He st.id h3 doesn't know.
What 11 you are really,doing is asking him to guess or 12 speculate.
13 MR. GLASSMAN:
He said he didn't know with
)
14 certainty,or assurety or something to that 15 effect.
16 MR. WISE:
I think you have asked the 17 question as to whether it did or did not.
He i
18 told you he doesn't know.
To then go further i
19 and ask him for an opinion is essentially asking 20 the same question again hoping to get a 21 different answer.
I don't think it is proper.
i 22 I object to the' form of the question and 23 if the witness wants to venture an answer I f
l 24 suppose he can.
I will not direct him not to l
/s s-25 answer.
e Y
A
l 1
LaBolle 137 1
l (3) 2 I think the question is improper and I 3
don't think it is valuable given his previous 4
answer.
5 BY MR. GLASSMAN:
I 6
Q Mr. LaBelle, will you please answer the i
7 question?
8 THE WITNESS:
Will you repeat the question, l
P ease?
9 10 (The pending question was read by the j
l 11 reportar.)
12 A
No, sir.
13 Q
Mr. LaBelle, have event tree analyses (190%C 14 subsequent to the TMI-2.-accident related to sequences A
(
(S0b J
15 of eventsAthat were not analyzed prior to the TMI-2 a
16 accident?
17 A
I do not understand the sequence of events that 18 you are referring to.
f 19 Q
Have any sequences of events been analyzed
!J 20 under the event treeanalysisdonebyq]4jWafterthe i
21 TMI-2 accident which event or sequence of events had h
i il' 22 not been analyzed prior to the TMI-2 accident?
a 23 A
I do not know.
24 Q
Have event tree analyses performed by B I
25
& W subsequent to the TMI-2 accident included analyses
'y\\
1 1
I 1
LaBelle 138 2
of events leading to the opening of the PORV and the O-M f-3 resultant loss of coolant acciden 4
A I do not know.
5 Q
If you wanted to. find out, who in %3(]R
+
6 would you ask?
f 7
A The individuals that are involved in the (AT~o&)
8 anticipated transient operating guidelineAprogram for 9
the B & W owners group.
10 Q
Which individuals are they?
I J
l 11 A
I do not know.
d 12 Q
Under the heading " Event Tree Simulation" (W W 1979 memo contained in GPU Exhibit-273 13 on the May 1, A
)
14 marked for identification, the lead unit is indicated 15 as being Safety Analysis /ECCS.
16 Does that mean . sat there were two lead 17
' units?
18 MR. WISE:
Excuse me.,
You are now speaking 19 about the recommendations that Mr. Vosburgh and 20 Mr. Bonoca were making or are you speaking about 21 something that in fact happened?
It is unclear 22 from your question.
23 MR. GLASSMAN:
Mr. Wise, I don't think we 24 need your input on what this means.
I think I 25 was very plainly asking a question regarding the e
m I
1 LaBelle 139 I
'fhDIO s
2 May 1, 1979 memorandun..
A 3
I d n't think that the witness needs any 4
more coaching from you as to the nature of the 5
memorandum.
l 6
MR. WISE:
I object to that, Mr., Glassman, I
7 and it's been a continual thing with you that 8
every. time an objection is made you accuse 9
opposing counsel of. coaching.
10 Your questien is improper in form and I 4,
11 direct him not to ancwer.it and let's go ahead.
)!
12 If you want to proceed that way -- and I thought 13 I was trying to help by clarifying the situation
()
14 so that you could proceed.
15 If.you want to play lawyer, we can do it 4
16 that way, too.
t 17 MR. GLASSMAN:
I don't know how my question 18 could be clearer.
j 19 MR. WISE:
It is improper.
It assumes 20 facts 'not in evidence, and I can support that I 21 think if you want to have the record repeated.
22 Your choice of verbs indicated a fact.
That 23 fact has not been established.
e 24 BY MR. GLASSMAN:
l
[
25 Q
Mr. LaBelle, was Phase l of the event tree
~~
J
__;_ % 1 1
LaBelle 140
@f}DSO
[
2 simulation as referred to in the May 1,
1979amemo
,a 3
which is a part of GPU Exhibit-273 marked for 4
identification ever implemented?
5 A
I could not say that it was ipplemented in 6
its entirety, no, sir.
7 Q
Was it implemented in whole or in part?
8 A
I do not know for a fact that it was.
9 Q
The May.1, 1979 memorandum recommends 10 implementation of Phase-1; is that, correct?
I 3
11 A
You are referring to which?
12 Q
I am referring to the May 1, 1979 13 memorandum which is contained in GPU Exhibit 273 14 marked for identification.
15 A
But you are referring to the memo from Bonoca 16 and vosburgh to myself?
17 Q
Yes.
4j They.have offered, according to this memo, a 18 A
. 19 recommendation, yes, sir.
20 Q
Did you forward that recommendation to 6 90S0 }
21 your superiors?
4
[
}
1979 memo from myself 22.
A According to the May 7th, 4
23 to Dr. Roy and Womack, Exhibit 273, it says here that 24 I did.
25 Q
Do you have any reason to believe that
[u) i
w
_w
~
~
LaBelle 141 1
[')s
(
2 y u did not take that action?
A N
- sir, 3
ii Q
Does the recommendation under Phase-1 4
f.1-lead include a listing of.two lead units for event tree l;
3 5
l l
simulation?
6 A
It just states here two lead units in this memo 1
i 7
1$0$Ol 8
Of.May.lst, 197 I
Q why was there a recommendation made that 9
4 a lead unit?
10 Safety Analysis and ECCS work together as j
4 i !
MR. WISE:
I object to the form of that 11 i
12 question.
If the witness wants to venture an answer I will permit him to do so.
13
-~
1 14 A
I could not say.
i 15 Q
Had there been any instances prior to the 16 TMI-2 incident in which Saf,ty A7alysis and ECCS had l
17 formally, worked together on a project?
Safe and the Emergency Core Cooling h % $q. Analysis 18 A
/
^
System 4 nit are sister units performing analyses that U
19 (SAS) 1
(
20 are provided in the Safety Analysis Reportapertaining to transient and accident analysis.
21 i'
h 2?
Q What do you mean by " sister units"?
r 23 A
The ECCS Unit provides information pertaining d.Od8) the loss of coolant accidengp 24 to l
25 Q
In working as sister units were the two s.
4
r
~~~
1 LaBolle 142
-Ull 2
unitsArequired to interchange information?
A No.
I will qualify that by.saying that 3
4 information provided by the ECCS unit would be 5
coordinated into the accident analysis chapter of 6
the Safety. Analysis Repor 7
Q I would like you to refer to the next
- I 8
page of GPU Exhibit--273 marked for identification, (l90$O 9
which is Page-J of the May 1, 1979 memorandum.
4 i !
10 I would like you to read the first
.2*/1NhCe-D 11 sentenceAof the paragraph listed under Phas M j
12 relating to the analytical f ollow-up to Phase--I and
]
13 tell us whether such a progism was ever in effect 14 prior to the TMI-2 accident.
1 j
15 A
Not in terms of event tree analysis.
l 16 Q
What is meant by.the term or terms:
f 17
"...to assure bounding SAR analysis are in place"?
i 18 MR. WISE:
I will permit him to answer to 19 the extent he has an understanding.
I object 20 to the form of the question on any other basis.
i 21 A
This is a reference to the existing Safety 22 Analysis Report analysis.
l 23 Q
In what respect might the bounding SAR
\\
24 analysis not be in place?
25 A
I do not know.
.,_m.
5 1
LaBelle 143 2
Q What was your understanding of why this 3
capability must lie in the Safety Analysis area?
4 A
As I mentioned previously, I have no opinion to
}
5 offer in that area.
i 6
Q What was your understanding?
7 MR. WISE:
His understanding of what?
He 8
said he had no opinion.
9 MR. GLASSMAN:
I didn't ask that question.
10 Perhaps the reporter can read back the I
{
11 question.
12 (The question referred to was read by the 13 reporter as requested.)
14 MR. WISE:
What was his understanding of 15 what?
16 THE WITNESS:
Could you go back several i
17 questions?
18 MR. WISE:
Let him rephrase the question.
I 19 MR. GLASSMAN:
I think I will put it back 20 on the record so the record is clear, Mr.
(
21 LaBelle.
1 22 BY MR. GLASSMAN:
23 Q
What was.your understanding, sir, of why 24 this capability must lie in the safety Analysis area?
25 MR. WISE:
I object.
Can we have the t-i
E
._1._
^
1 LaBello 144 (O
I 2
reporter read back the question two before?
I think it is the exact same question.
3 4
MR. GLASSMAN:
That.was precisely what I 5
wanted to do to make sure we have the proper 6
question on the record before the witness.
l 7
(The record was read by the reporter as 8
requested.)
9 MR. WISE:
While we were off the record i
I' 10 we have had the question reread.
It is the i
11 identical question which Mr. LaBelle already 12 answered by.saying he doesn't have an opinion.
l I
13 Counsel indicated he wanted to make sure
- 7.,
' )
14 that Mr. LaBelle in his answer is also including 15 whether he has an unders.tanding besides an 16 opinion.
17 To that extent, I will permit Mr. LaBelle i
18 to clarify' whether in his previous answer he 19 meant to include a laux of understanding as well 20 as a lack of opinion.
21 A
Before I provide a response it would be helpful 22 to me to understand what was meant by " capability" in 23 your question.
24 Q
Did you understand that a capability to
,x
(
)
25
" evaluate all branches of event trees to assure bounding
! Ns
__,c 1
LaBelle 145 2
SAR analysis are in place and to identify.those areas where operator error and/or ICS failure will propagate 3
to a limiting situation," that such a capability must 4
r should lie in the Safety Analysis area?
5 I
6 A
The entire capability.should not exist in the j
7 Satsty A'nalysis Unit.
(
8 Q
Why could it not exist in the Safety 9
Analysis Unit?
10 A
To the extent of understanding the entirety 11 of system -- systems interaction and operator 12 effects, also to the extent of the responsibilities 13 that the unit had for certain transient and accidents >-
(
14 transients and accidents.
15 Q
Did Messrs. Vosburgh and Bonoca communicate 16 to you in words or substance a recommendation that the 17 entire capability should lie in the Safety Analysis 18 area?
19 A
No, sir.
20 Q
What capability did you understand Messrs.
21 Vosburgh and Bonoca to be referring to in this paragraph (MosoQ 22 on Page-2 of the May 1, 197,9 memorandum?
4 23 A
You keep referring to capability.
Capability 24 for what purpose is where I have difficulty in trying
's 25 to recall their interest at the time this particular L
t.
1 LaBolle 146 N
2 memo was issued.
3 Q
At or about the *:ime this memo was issued 4
did you feel that the responsibilities of the Safety S
Analysis Unit should be expanded?
I 6
A If the activity. suggested here was to be i
7 Performe~d within the unit,yes, sir.
Make that safety
{
8 Analysis Unit.
9 Q
Do you know if.the recommendation
{8 0501) 10 contained in Phase-3 on Page-2 of the May 1, 1979A 11 memo was ever carried out in whole or in part?
12 A
No, sir.
13 Q
Under the heading " Computer Code s
14 Modifications and Devel'opment" further on on this r
15 Page, the paragraph.begins with the statement:
16 "The current versions of CADDS and TRAP-A fare adequate for licensing type analyses..."
17 18 Can you tell us what TRAP 2 is?
i 19 A
TRAP 2 is a CRAFT code derivitive with a more
$Y 20 detailed steam generatorgmodel.
1 l
21 Q
Do you know what the acronym TRAP stands t
22 for?
l 23 A
I just cannot recall, sir.
24 Q
Did you agree that the current versions e
i 25 of CADDS and TRAP 2 were adequata for licensing type
' V t
4
]
1 LaBelle 147 2
analyses?
w A
These codes were adequate to the extene that 3
4 they had been accepted by the Nuclear Regulatory commission (N Afor performance of accidents and transient 5
i e nditions which the safety Analysis Unit was i
6
' 1, j
y responsible for in preparation of the accident
'l 8
analysis section of the Safety Analysis Report.
l 9
Q Is there any respect in which the current 10 versions of the CADDS and TRAP =4 were inadequate for
,i 11 licensing-type analyses?
i i
12 A
They were adequate to the extent of application 13 for which they. ware licensed by the Nuclear
()
14 Regulatory Commission for transient and accident 15 analysis.
i 16 Q
The same sentence of GPU Exhibib-273 17 marked for identification continues with the statement 18 that:
j 19
"...they are not adequate for more 20 complex or ' realistic' situations."
1 21 Do you agree with that statement?
4 l
22 A
I do not know what the author's interpretation 23 of " complex" might have referred to.
In terms of 24 realistic analysis, I would concur with that t
25 particular statement.
e-
~ -
1 LaBelle 148 2
Q What do you mean by the term " realistic" 3
in this context?
4
-A These codes were for licensing-type analyses 5
and were not designed for operational-type analyses.
,t 6
Q What is the difference between licensing-7 type analyses and operational-type analyses?
[
I l
8 A
Licensing-type analyses would refer to the t
conservative or bounding-type an.. lysis provided in the 9
(SA0 safety. Analysis ReportA or the accident and transient -
f 10
.I 11 analysis.
4 12 Q
How does that differ from operational-type 13 analyses?
14 A
Operational analyses-is just that, the functioning 15 of each piece of equipment in accordance with its 1
(
16 normal operation.
17 Q
Is that based on actual operating
~
t 18 experience?
i 19 A
I do not understand what you mean in terms of 20 "is that based on."
i 21 g
what is meant by the term " normal 22 operation" when you speak of the functioning of each l;
l I
1 23 piece of equipment in accordance with normal operation?
24 MR. WISE:
Do you want him to define the 25 words " normal operation" for you?
4 1
)
1 LaBello 150 2
Q Have you seen any approval letter from O
the NRC on those codes?
3 4
A It is possible that I have, but not that I can
- t 5
recall having seen.
i'I 6
Q If you wanted to find such letters if they
,(
7 existed *would you also go to the licensing group?
8 A
Yes, sir.
l 9
Q Further on in the same paragraph there is 10 a reference to " department level priority."
What does i
4' 11 that mean?
1 12 A
That.is in the sentence:
"These mods will be 13 requested..."?
l
)
14 Q
Yes, that is. correct.
15 THE WITNESS:
Okay.
Could you repeat that 16 question for me, please?
17 (The pending question was read by the 1
18 reporter.)
19 A
Department level would refer to the engineering 20 department and that these code changes for development 21 of operational models would receive priority at that 22 engineering department level.
i 23 Q
Do you agree that these program mods will i
24 be required regardless of future user's group work?
25 A
You are referring here to the words in the next l
r
7 1
LaBelle 149 2
MR. GLASSMAN:
Yes, as he understands it 3
in this context.
4 A
It is the way that the equipment operates.
i er 5
.Q Was the CADDS code aver approved by the 6
NRC7 7
A As far as I know it is.
8 Q
What is the basis of your knowledge?
9 A
The code has been used in previous SAR 10 licensing efforts and those Safety, Analysis Reports l
11 have been licensed.
12 Q
Is there an'y.other basis for your 13 statement?
(D
\\s /
14 A
There could be a concurrent letter to ([MCN 15 stating the acceptance of the code for licensing by 16 the Nuclear Regulatory Commissions 4
17 Q
Have you ever seen s"ch a letter?
l 18 A
Not that I can recall.
j 19 Q
If you ' wanted to find such a letter f
20 where would you look?
21 A
With our licensing group.
22 Q
Were the CRAFT or TRAP-2 codes ever 4
23 approved by the NRC7 f
24 A
To the same extent of what I have said i
[J~'h 25 previously about the CADDS code.
1 LaBelle 151 2
sentence?
3 Q
That is correct.
4 4
A I am not sure that I could go as far as to say i
5 that they will be required.
I 6
Q was it your recommendation that program i
'j 7
mods sho'uld be required regardless of future user's
,l-8 group work?
l i
9 A
No, sir.
10 Q
Did you disagree with the statement in the i
11 last sentence of.that paragraph that the mods will i
12 be required regardless of future user's group work?
13 MR. WISE:
I think in fairness to the 4
')
1<
record we ought to have the whole sentence put J
15 in just so that someone reading this knows what 16 it is we are talking about, since there have i
17 been several references to parts of this 18 sentence.
i 19 The sentence in its entirety reads:
20 "From current NRC analysis requests, these 4
21 program mods will be required regardless of future 22 user's group work."
23 BY MR. GLASSMAN:
24 Q
Will ycu please answer the question?
I 25 A
I think in reading the sentence that if the
- O t
(
% C --
. __._a._:.
1 LaBelle 152 2
"will" were changed to a "may" that it would be more 3
in keeping with my particular feelings at that time.
4 Q
If the program mods were required or micht 5
be required regard 1ess of future user's group work, i
6 does that mean that $3(]Fwouldpay for the program
!l 7
mods?
!{
8 A
I could not say at a11 with respect to that.
9 Q
I would like you to refer to the next page 10 of GPU Exhibit-273 marked for identification under 1
1 11 the heading " Equipment Modification Recommendations."
j 4
12 It begins with the sentence:
13 "One of the most usefu1 pieces of I
O).
(_,
14 information that will come from the event tree 15
~ analysis will be those paths that lead to 16 severe results with high probability of 17 occurring."
18 Did you have any particular paths in mind 19 at that time?
20 A
No, sir" 21 Q
Under the heading " Approach to Safety 22 Ana1ysis" on the same page of GPU Exhibit-473 marked i
23 for identification there is a paragraph beginning 24 with the following sentence:
25
,h.
most 1., ort.nt, ane s.ee.st. 1esson c;;)
4 1
~%
1 LaRollo 153 l
2 learned from TMI-2 is the general complete lack of 3
knowledge concerning reactor safety."
i 4
Did you agree in whole or in part with 5
that statement?
i l
6 A
Where are you at now?
7 Q
I am reading from the first paragraph under 8
the heading " Approach to Safety. Analysis."
9 A
Okay.
10 THE WITNESS:
Coald y'ou repeat the ii i l' 11 question, the part that was mentioned?
4 j
12 (The pending question was read by the Il[I 13 reporter.)
1 s
i N
14 A
Thia.is a statement by Juc. Banoca and Mr.
15 Vosburgh expressing their feelings.
16 Q
Did you agree in whole or in part with 17
- that statement?
i 18 (
A I could not state that I agreed in whole or in j
19 par't with that statement.
20 Q
Did you disagree with that statement?
' 21 A
I could not state that I' disagree with the
/:
{
22 statement.
It is not my statement.
1 ju Q-Did you agree that there was a lesson i
i 24 learned'from TMI-2 of any type regarding the lack of f
.S is kno.1.eg..on..rning rea. tor sa,.t,7 c)
m.
w.
1 LaBello 15U
^
2 A
I am not sure what is meant by " lack of knowledge 3
concerning reactor safety."
~~
j 4
Q Was there a lack of xnowledge'within ( Q 5
concerning reactor safety prior to the TMI-2 e
6 accident?
s.
7 A
Again, I would have to repeat, that lack off
~s 8
knowledge conce'ening reactor safety was a very general 9
phrase and I do >i no t know what is, intended by that s
t 10 phrase.
t 4
l-j 11 Q
Was there a lack of knowledge within s
t 12 B & W concernincy any. aspect of reactor safety?
13 MR. WISE:
I don't know that that is a s
v/
14 fair question to ask the witness.
I will object 15 to the form and permit him to answer to the
\\
16 extent he can.
17 A
Again, it is too general a question for me to be.
s 18 able to respond to.
19 Q
When you forwardsd this memorandum on to 20 your supervisors did yW 2 dicate to them orally or sith that statement?
21 in writing any disag.,.. era w, 22 A
Not that I 3an re call, since the process that t
23 was followed was one of escalating to my superiors l
24 the comments of Mr. Vosburgh and Mr. Bonoce as they ll w
1 l
25 were written.
- s. s,
- p N.,)
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i C
h k
l t-1
m r(
t s-
' (\\
LaBelle 155 1
i 2
Q I would like you to read to yourself the O,
Ndi statement under the indented paragraph-(l) under the 3
g 4
heading " Approach to Safety Analysis" and tell us 5
'whether you agreed,in whole or in part with that 6
statement.
I J
7 A
I~could not say with assurety that I understand I
4 t
2 the entirety of the paragraph that has been written by
'\\
g t
u i
J
'a 9
Mr. Vooburgh and Mr. Bonoca.
I would agree that the i
u'u l' ct '3, 10 responsibilities of the Safety Analysis Unit was h
[,
,f X
11 limited to safety evaluations that were used to 12 support licensing activity.
13 Q
Did you feel that the responsibilities of
()
/
14 the Safety Analysis Unit should be broader than the 15 support of licensing activity?
,:(
k 16 A
I think, as any manager of a unit, one is quite
.\\,
i 17 interested in increasing one's responsibilities, yes, 9 N q) j' 18 sir.
t 19 Q
What were the reasons for your interest 20 in broadening your responsibilities in safety g
i
'21 Analysis?
4 "s
b j
.F, 22 A
okay.
As stated in this particular paragraph, P
l 23 these -- the information as stated are the opinions of 24 Mr. Vosburgh and Mr. Bonoca such that any opinions a
i 25 that I would offer with respect to my personal feelings
~t
,)
c
!a
\\
+c i
ty h.r LM
i 1
LaBelle 156 about expansion of the Safety Analysis Unit 2
U,N responsibilities would have no direct bearing on - this 3
4 particular paragraph.
5 Q
I w uld like you to answer the question
-l 6
without regard to the paragraph.
If you like, we can have the' question repeated to you again.
7
{
8 A
Okay.
MR. GLASSMAN:
hi. Reporter?
9 10 THE WITNESS:
Will you please repeat the 11 question?
12 (The question ref err'ed to was read by the 13 reporter as requested.)
j 14 A
This would be primarily.from an. administrative w/
15 standpoint working with a bigger working staff and i
16 work responsibilities.
17 Q
Were there any.other reasons.for your 18 interest in broadening responsibilities of the Safety 19 Analysis Unit?
i 20 A
No, sir.
21 Q
Did you ever consider performance of 22 safety analyses which were not strictly in support of l
23 the licensing requirements?
24 A
It is certainly possible.
t i
25 Q
Do you recall any such consideration which g-~s I
k.-
t
- - = _
m 7
1 LaBelle 157 f
-5 2
you gave to that issue?
,V-A No, sir.
3 4
Q Did you discuss the words or substance of l
5 Item 1 under the " Approach,to Safety Analysis" 1
6 contained in GPU Exhibit-286 marked for identification i
l 7
with either Messrs. Vosburgh or.Bonoca?
8 THE WITNESS:
Could you repeat that 0
question?
I didn't hear the first part of it.
10 (The pending question was read by the t
{
11 reporter.)
12 A
I can recall the discussion, yes, sir.
f 13 Q
With whom did you have such a discussion?
()
14 15 A
With both Mr. Bonoca.and Mr. Vosburgh.
16 Q
Was it a meeting between the three of you?
17 A
Yes, sir.
/18 Q
What did you say to either of these 19 gentlemen and what did they say to you?
20 A
I have no recollection.
21 Q
Can you give us the substance of what you 22 said to them and what they said to you?
23 A
No, sir, I ca%)not.
24 Q
What do you recall of such a meeting or 25 conversation?
)
L
--e_ _ - - _ _.
]
s l
1 1
LaBelle 158 2
A Just that there was a meeting.
3 Q
You have no recollection of the words or 4
substance of such a meeting?
5 A
No.
6 Q
Did you have such a meeting prior to 7
forwarding their memo on to your supervisors?
8 A
Yes, sir.
9 Q
Did you suggest to them any changes in
}
10 their memorandum to you, what is finally embodied in I
(1405bl) i 11 the May 1, 1979Amemorandum to you?
12 A
I may.have.
j 4
13 Q
Do you recall any.such discussion?
s_
14 A
I can recall having m..de rscommendations, yes, f
15 sir.
f 16 Q
Can you tell us what they were?
t 17 A
No, sir.
18 Q
Did you have any notes with regard to such 19 recommendations or discussions with Messrs. Vosburgh 20 or Bonoca?
?
21 A
Not that I can recall.
k' i
22 Q
Do you know if any drafts were prepared i
l 23 of the May 1, 1979 memorandum?
l 24 A
No, sir.
25 Q
Did you discuss the words or substance of 4
4
,.,,,.,,.,-,v,--.
,,------n
--~~ -.,-,-- -,,,,,
,,,.,.,--..,,,--,,,c---
1 LaBelle 159 2
Item-1 under the heading " Approach to safety Analysis"
\\#
with'Dr. Roy or Dr. Womack?
3 A
I cannot recall any such discussions.
4 Did y(ou either mark up or retain 5
Q a copy MossD i
6 of.the May.1, 1979 memorandum?
jt
'7 A
N o't that I can recall.
g Q
Under Item-2 there is a sentence which 9
begins or reads as follows:
10
" Decisions regarding plant safety, or
)
11 equipment qualify and functional specifications, i.
12 must be made within Saf ety Analysis (and ECCS). "
13 In what respect would this.be different
(~-)
14 from the practice prior to the TMI-2 accident?
/
15 MR. WISE:
I am going to object to the 16 form.
The witness may answer it if he can.
17 A
okay.
18 THE WITNESS:
Could you repeat the 19 question, please?
20 (The pending question was read by the 21 reporter.)
l 22 A
The statement as presented by Mr. Vosburgh and I
i 23 Mr. Bonoca is a very generaT. statement and I would k.
[
24 repeat, as I said before, that the Safety Analysis i
e 25 Unit was responsible for accident and transient t
(
i 4
w ---
n.
1 LaBelle
-160 (Sfl
(
-2 analysis for the Safety Analysis Reporg.
3' Q
Under Item-4 under the subheading a
4
" Approach to Safety. Analysis" there appears the 5
following sentence:
i 6
"The degree of decisions made affecting P ant safety,outside of Safety Analysis during l
7 0005 8
the TMI-2.incidentgwas appalling, although 9
recognized as necessary.under the current mode 10 of operation."
)
11 Did you discuss the words or substance of 12 that sentence or Paragraph-4 with Messrs. Vosburgh 13 or Bonoca?
14 A
I cannot recall having done so, no, sir.
15 Q
Did you~ agree in whole or in part with 16 that statement?
17 A
This was their opinion.
I did not have to agree 18 or disagree with their opinion.
19 Q
Did you agree in whole or in part with 1
20 that statement?
21 MR. WISE:
I think he has just answered.
22 MR. GLASSMAN:
He did not answer the i
23 question, Mr. Wise.
t 24 MR. WISE:
I heard an answer and I think f
25 the reporter got one on the record.
(}
1 LaBelle 161
\\
2 MR. GLASSMAN:
That doesn't mean it was 3
resp nsive, Mr. Wise.
I think we can have a 4
simple answer.
We understand your point.
5 MR. WI'SE:
.I think it was responsive.
I
+
6 don't.think necessarily I am confined to your 7
vi'ew of what is responsiva or not.
I think he i
j 8
has answered the question.
9 BY MR. GLASSMAN:
1 10 Q-Mr. LaBelle I
t 11 MR. WISE:
We can have it repeated if you i
12 like.
13 MR. GLASSMAN:
Why, don't we do that.
f) 14 '
MR. WISE:
Yes, I think that is a good s/
15 idea..
16 (The record was read by the reporter as 17 requested.)
3 3
18 MR. WISE:
Off'the record.
19 (Discussion off th.e record.)
20 MR. WIS'E:
Mr. Glassman is apparently 21 confused by your answer as to whether you did j
h 22 or did not agree at the time with the portion of i
23 the document that he has read to you.
24 Can you clarify for Mr. Glassman the 25 meaning of your answer to the previous question?
)
.I 4
6
,,.,.,-,-.v-
- - = _ _
y 5
A 1
LaBelle 162 O
)
2 THE WITNESS:
Okay.
A I did n t feel at the time or at the present 3
4 time that I have to agree ob di'ssgree with the P nions of Mr. Vosburgh or Mr. Bonoca who were working i
5 6
for me.
7 Q
Mr. LaBelle, so we don't waste too much 3
time, I am not asking you whether-you had a l
a 9
respons>bility.to have to agree.
I am only asking for i
10 your state of mind whether you in fact agreed in whole i
11 or in part with that statement.- Yes or no?
12 MR. WISE:
Do you understand what you are 13 being asked?
14 THE WITNESS:
Yes.
15 MR. WISE:
No one-is asking you to look at 16 this thing at this point.
All he is asking you 17 is did you have an agreement or a disagreement 90500) 18 in or about May 197 with that particular 19 statement as a matter of fact regardless of what 20 responsibilities you may have had.
21 A
I had no agreement or disagreement with that 22 scatement.
23 Q
Referring to the last page of GPU Exhibit-286, 145 Mr. LaBelle, under the heading " Conclusions,"
24 f
25 the final sentence concludes:
i:
?
I
.1, d
- _ - ~
t i
LaBelle 163 2
"... a strong. central Safety Analysis 9r uP must emerge, precluding the fragmented, 3
4 self-styled safety ' experts' that currently exist throughout the engineering organir.ation."
5
- )
i 6
Did you ever discuss that statement with Messrs.'Vosburgh or Bonoca?
7 e
8 A
Yes.
i
}
g Q
Can you tell us the words or substance 10 of.your discussion with Messrs. Vosburgh or.Bonoca II
)*
11 in this respect?
1 12 A
Only.that this partien'.ar statement was a i
l 13 philosophical concern that Mr. Vosburgh and Mr.
f ()
14 Bonoca had.
i 15 Q
Did you agree in whole or in part with 1
e 16 that otatement?
{'
17 A
I agreed to the extent that safety is a very l
18 general term and that the Safety Analysis Unit had i
i l
19 defined responsibilities and that other decisions I
20 that were being made with respect to safety did not 21 infringe upon the Safety Analysis Unit's f
h 22 responsibilities.
e 23 Q
Did you have any.other prior decisions j
24 in mind which infringed on the Safety Analysis Unit's i
I 25 area?
I i
e L-
n 1
LaBolle 164
<~x 2
A Not that I concurred with, no, sir.
/
T t\\"
3 Q
Did you have other decisions in mind that 4
you did not concur with?
A I am.not sure I understand the substance of 5
6 your question.
7 Q
I understood from your prior. answer, Mr.
I l
8 LaBelle, that there were such prior decisions that i
9 infringed on the safety Analysis area that either you I
10 did not concur in or that you d!1 not believe 11 infringed on the Safety Analysis areas is that 12 correct?
l 13 A
I did not feel that the responsibilities that e
li
)
14 the Safety. Analysis Unit had were being infringed on,
~.a 15 no, sir.
16 Q
Did you communicate your feelings to Dr.
17 Roy or Dr. Womack in this regard?
18 A
I can recall no reason for having to do so.
19 Q
Did you discuss the conclusions of the (19o50l) 20 May 1, 1979 memorandum or the substance of those A
21 conclusions with Dr. Roy or Dr. Womack?
l h
22 A
I could not say that I didn't, but I cannot i
j 23 recall.
f 24 Q
Did you attend a meeting of plant design I
(190SoA (790400) l7 25 unit managers in May4or June of 19797 4
) !(
4
, j x_/
i
1 LaBelle 165 A
I don't know.
2 Q
Was any p rtion of GPU Exhibit-486 or the 3
4 substance of the memoranda contained therein discussed 5
at any. plant design unit managers meeting?
6 A
Not that I can recall.
+
7 MR. GLASSMAN:
Off the record.
8 (Discussion off thc record.)
9 (Recess taken.)
fI3 MR. GLASSMAN:
I would like to have b!
11 marked as GPU Exhibit-487 for identification (A=~Sh8SiSh 12 two sheetsA of paper, hand written, with the 13 heading " Potential Lessons to be Learned from
[
14 TMI-2."
s 15 (The document above referred to, headed i
16
" Potential Lessons to be Learned from TMI-2,"
1 17 consisting of two pages, was marked as.GPU 1
18 Exhibit NQ)Cd87 for identi:ication as of this date(g)loboC 19 4
20 BY MR. GLASSMAN:
21 Q
Mr. LaBelle, I show you what has been 22 marked as GPU Exhibit 287 for identification (handing 23 document to the witness).
Can you tell us what this l
i 24 document is?
(
25 A
This is a listing of potential lessons to be
%)
g.
_p 1
LaBello 166 2
learned from TMI-2 referring to the TMI-2 incident
'1003Sh 3
f March 28th, 197 gas prepared by myself.
your si appear at the bottom 4
Q Does (pge-A)gna ture t
5 of the second pagegof.this document?
6 A
Yes, sir.
7 Q-Why did you prepare this document?
l I
8 A
As best I can recall it was prepared at the g
request of Dr. Womack.
10 Q
Was Mr. Womack's request oral or in 11 writing?
l 12 A
As best I can recall it was oral.
13 Q
Did Dr. Womack make this request in a l
14 meeting of plant design unit managers?
(
15 A
As best as I can recall that is correct.
16 Q
Did he request such a statement of all 17 plant design unit managers?
18 A
As best I can recall that is correct.
19 Q
Under your signature on Page-2 there
("fQ0%5) 20 appears a date of 5/25/79 Do you recall approximately g
21 when the meeting of plant design unit managers took
)
22 place at which Dr. Womack's request was made?
l 23 A
No, sir.
24 Q
How did you go about preparing this 25 document?
O'-
I A
One#pY~ePares a document.
.. ~ - - -
1-LaBelle 167
)
2 Q
Did you obtain input from any other 3
Persons?
4 A
Not that I can recall, p
5 Q
Did y u review any written materials i
6 prior to preparing this document?
A I could have.
7 8
Q Did you make or retain any copies of any 9
materials you reviewed?
10 A
I don't know.
11 Q
Did you review GPU Exhibib-286 marked for i
~
12 identification in whole or in part in the course of
- i
]I 13 Preparing GPU Exhibit--287 marked for identification?
4 i
t l
\\_
14 A
.I do not know.
1 15 Q
Do you have a file or files relating t6 2
16 this document or its preparation?
17 A
Not that I can recall.
i I
18 Q
Can you tell us the words or substance of 19 Dr. Womack's request to you?
1 j
20 A
Not specifically, no, sir.
21 Q
Can you tell us generally?
h 22 A
There was a request for each unit manager to i
I
.s 23 submit a list of what we f e? c, were some of the 24 Potential lessons to be learned from the TMI-2 incident.
25 Q
Did Dr. Womack provide any guidance as to
()
i
L
-m.
~.. -
1 LaBollo 168
,I 2
the type of lessons to be learned or what else he had V
3 in mind?
4 A
Not that I can recall.
5 Q
Did Dr. Womack state to you the reason for 6
the request?
I 7
A Not that I can re6all.
8 Q
Do you know the reasons for the request l,
I 9
from any other source?
10 A
No, sir.
11 Q
The first paragraph of GPU Exhibit-287 4
12 reads as follows:
1 13 "0Perators are not prepared to cope with
,3
/
' _,/
14 abnormal operating conditions which do not 15 align closely.with anticipated and design basis 16 conditions, including multiple failures and 17 inappropriate prior operator actions.
Event 18 diagnosis is much more complex than operators 19 have been led to believe."
20 In what respects was event diagnosis much j
21 more complex than operators had aeen led to believe?
l 22 A
This was just a general statement.
I 23 Q
What was the basis of your statement?
i 24 A
Just in looking to the future that it would be
[']
25 recommended that event diagnosis be given further s _.-
I I
t-
I LaBelle 169 2
consideration.
e'
\\'~ )
3 g
What had operators been led to believe 4
regarding event diagnosis prior to the TMI-2 accident?
5 A
I do not know.
Li 6
Q What did you have in mind when you wrote i
f 7
this sen'tence?
8 MR. WISE What did he have in mind about I
9 what when he wrote the sentence?
10 MR. GLASSMAN:
What did Mrs LaBelle t
t 11 have in mind when he stated that operators had l
12 been led to believe that event diagnosis is
]
13 more complex -- excuse me; just let me restate 1 ( ),
/'
14 that.
%d 15 That became slightly garbled.
I think 16 the question was probably clearer at the 17 beginning, but I will restate it.
18 MR. WISE:
It wasn't to me, and the fact t
19 that we are having a little difficulty figuring l
20 out what it is now leads me to believe it should
(
21 be clarified.
I h
i
- l
.F 22 BY MR. GLASSMAN:
- I 23 Q
Mr. LaBelle, w;.a t did you have in mind with I
24 respect to what operators had been led to believe 25 concerning event diagnosis as set forth in the last
\\)
i
?
4
1 LaBelle 170 2
sentence of this paragraph?
A I had nothing specific in mind other than to 3
recommend that this be one area that should be further 4
understood and looked at.
5 6
Q Had you discussed the complexity of event 7
diagnosit in words or substance with anyone else-8 before you~ prepared this document?
A Not that I can recall.
9 10 Q
Was this an accurate reflection of your
{
11 state of mind?
I 12 A
Since I wrote it at that time I would presume 13 that it is.
I.4 Q
In what respect were operators not prepared 15 to cope with abnormal operating conditions which do 16 not align closely.with anticipated and design basis 17 conditions?
18 A
The fact that the TMI-2 incident had occurred.
19 Q
Was B[hCN familiar with abnormal operating 20 conditions which did not align closely with anticipated i
21 and design basis conditions?
22 MR. WISE:
Was B & W familiar?
I will 23 object to the question.
24 If you can figure out what that question 25 means you may answer it, Mr. LaBelle.
1 LaBelle 171
(
2 A
It's a very general statement.
I don't know U
that I could answer it.
3 4
Q Mr. LaBelle, at the time you prepared 5
GPU Exhibit-287 marked for identification were you 6
aware of any.. abnormal operating conditions at TMI-2 g
7 which did not align closely.with anticipated and l
8 design basis conditions?
9 THE WITNESS:
Could you repeat the i
10 question, please?
l 11 (The pending question was read by the 12 reporter.)
13 A
No, sir.
14 Q
What was the basis of your statement that 15 operators are not prepared to cope with abnormal 16 operating conditions whic.h do not align closely.with 17 anticipated and design basis conditions?
18 A
As I mentioned earlier, the fact that the TMI-2 19 incident had occurred.
I 20 Q
What aspect of the TMI-2 accident did not 21 align closely with anticipated and design basis g
1 22 conditions?
i 23 A
The overall combination of events that occurred 24 had not previously been included in the Safety Analysis
@nR) 25 Unit's contribution to the Safety Analysis Reporg.
L
E r
m 1
LaBelle 172
(
)
2 Q
To what combination of events are you 3
referring in your last answer?
C606) 4 A
To the sequence of event =A that occurred during 5
the TMI-2 incident.
6 Q
What sequence of events are you referring i
l q
to?
I 8
A The sequence of events.
l' Q
Can you tell us the sequence of events that 9
10 you have in mind so that it is clear on the record?
l 11 A
There were several sequence of events which were 12 prepared, all of which seemed to have general agreement l
l,r g 13 to my recollection.
These sequence of events were It l
~#
14 submitted by GPU, B[)CW and the Nuclear Regulatory h
15 Commissiongand perhaps others.
16 Q
Did the sequence of events include multiple 17 failures?
18 A
I cannot recall that ! c di t.
I will' qualify that 19 by saying it is a matter of what is meant by " multiple 20 failures."
i 21 Q
Why was the overall combination of events i
l 22 that occurred not previously included in the Safety
($/lh i
j 23 Analysis contribution to the Safety Analysis Reporg{
24 A
The sequence of events was not required for the
(
)
25 licensing plants by the Nuclear Regulatory Commission.
i
g 1
LaBello 173
.o Q-Is there any.other reason that the 3
overall combination of events that occurred on March 6903aD i
4 28th, 19794at TMI-2 had not previously been included i
5 in the Safety. Analysis contIibut*.on to the Safety i-(fAM) 6 Analysis Reportg 7
-A Th'a required analysis for the Safety Analysis 8
Report were those events which were deemed credible hh 9
by the Nuclear Regulatory.CommissionAand the nuclear a
10 industry..
< t
^
11 Q
Did the analysis actually.done for the SAR 12 include all events. deemed credible by, Babcock &
(f+ld]
[
13 Wilcox?g 14 A
Yes, sir.
i 15 Q
Had a similar sequence of events as 16 occurred on March 28th, 1979 ever occurred at another l-17 B & W designed plant?
l 18 A
Not the entirety of the event that occurred at a
19 TMI-2.
4 20 Q
Had an event occurred at another B & W d
l 21 designed plant prior o the TMI-2 accident involving a LON lossoffeedwate(rg,a l'
b stuck-open PORV and premature F
22 23 termination of HPI?
t f
24 A
I am not aware of the completeness of the I
25 sequence to which you referred.
' O I
e
1 LaBelle 174 i
O 2
Q Are you aware of~a transient at the Davis-(60 5) t 3
Besse plant that included that sequence of eventsgin j
,4 whole or in part?
- 5 A
I am aware of an event at the Davis-Besse plan't t
6 which included part of the sequence which you 7
mentioned.
8 Q
Which part of.the sequence did it include?
9 A
That there was an open PORV-type transient.
10 Q
Was the possibility,of a stuck-open PORV 11 ever referred to or included in the safety Analysis h
Report (6sgpreparedby.Bh(]h?
12 13 MR. WISE:
May,I have that repe'ated, l
P ease?
14 15 (The pending question was read. by.the 16 reporter.)
17 A
The particular occurrence of a stuck-open PORV 18 was not an event of which the Safety Analysis Unit 19 was responsible.
~ 20 Q
Regardless of whether or not this was the 21 Safety. Analysis Unit's responsibility, was the 22 occurrence of a stuck-open PORV referred to or 23 included anywhere in the Safety Analysis Report prepared 24 by B & W prior to the TMI-2 accllent?
25 A
I do not know.
c- _
c:-
1 LaBelle 175 2
Q Were you responsible as manager of the i
3 Safety Analysis Unit for coordinating the efforts of 4
various plant design units and their input to the hAd 5
safety Analysis Reporg(
t i
6 A
Yes,, sir.
7 Q
Did you forward GPU Exhibit -274 to anyone withinB(kW?
8 I
{
9 A
As best I can recall it was given to Dr. Womack.
k
!i 10 Q
Did you give it to anyone else?
t i
,i 11 A
Not that I can recall.
I 12 Q
Did you discuss the words or substance of d
fi i,1 13 the first full paragraph on GPU Exhibit-287 marked for
! l
'T
/
14 identification with Dr. Womack at any time?
15 A
Not that I-can recall.
1G Q
Did you discuss the words or substance of else at B & W at any time?
17 that paragraph with anyone i
18 A
Not that I can recall.
f 19 Q
Under the heading " Actions" after the 20 first paragraph on GPU Exhibit-287 marked for i
f 21 identification, the first sentence reads:
i g
F 22
" Identify vital information required for l
i' I
23 operator to make critical decisions to protect i
l l
j 24 the reactor core."
l f f 'T 25 What did you mean by the term " vital Q,) '
t I
t i
~..
1 LaBello 176 information"?
/
2
\\
A vital is vital.
3 j
4 Q
Did you have any particular vital 5
information in mind that you knew or understood was i
6 required for an operator to make a critical decision 7
to protect the reactor core?
8 A
No, sir.
9 Q
Were you referring to a technical ge ?
s 10 understanding of the reactor coolant systemg 1
11 A
The reference here is to any vital information 12 that would assist in protection of the reactor core.
I 13 Q
When you prepared this sentence did you 14 have in mind vital information that had not been 15 identified prior to the TMI-2 accident?
16 A
No, sir.
17 Q
Are you aware of any vital information which 18 had not been communicated by %)&OF to its customers 19 prior to the TMI-2 accident which information was 20 required for an operator to make critical decisions to 21 Protect the reactor core?
22 A
No, sir.
23 Q
The next sentence of GPU Exhibit-285 refers 24 to a provision for a "much more rigorous training 25 program."
In what respects were you suggesting a more
(
L
1 LaBelle 177 2
' rigorous training program?
A This was a general comment that the training 3
l 4
program be examined for inclusion of any. additional I
5 training that would be a. benefit to plant operators.
I 6
Q The next sentence in GPU Exhibit-287 7
reads as follows:
8
" Provide the plant operators with standard 9
techniques and improved equipment to recover 10 plant from unusual operating situations."
I i
11 Have I read your handwriting correctly?
(
12 A
Yes.
13 -
Q What improved equipment did you have in 14 mind?
15 A
I had no particular improved equipment in mind.
16 Q
Was there any equipment of which,you were (Y9032$
17 aware that was inadequate on March 28th, 1979 at TEI-27 4
18 A
No, sir.
19 Q
Why was it desirable to have improved 20 equipment to recover a plant from unusual operating 21 situations?
22 MR. WISE:
Why was it desirable to have 23
- improved equipment.
I will object to the form 24 of the question.
25 If the witness wants to answer it he can.
O a
1 LaBelle 178 2
A I do not know that it is desirable, but that in 1 king to future plant. operation if there are l
3 4
any. equipment improvements that could be of value to 5
the plant operation, one would want to recommend 6
those.
^
7 Q
Did you at any., time discuss any of the 8
items listed under " Actions" under Item-1 here in J
g words or substance with Dr. Womack?
10 A
I don't recall.any. discussions of'the action.
11 I would also point out that the Xerox has eliminated l
fibY~& (fblik-&
12 reference points 2 and'g, so that in order to clarify A
l
.13 your statement I would be referring to the actions
()
14 listed immediately.under the paragraph marked "1."
15 MR. WISE:
I might say.that it is not
,i 16 clear from the Xerox that it was the Xerox's 17 so much as it may be through whatever twist i
18 of fate the three-hole punch on this appears 19 to have obliterated the specific paragraph 20 numbering on the first page below Paragraph-l.
l 21 BY MR. GLASSMAN h
22 Q
Mr. LaBelle, was this document maintained j.
23 in a looseleaf binder of any. sort?
24 A
Since it has holes in it or appears to have l
25 holes in it that may be the case.
4 4
E
1 LaBelle 179
[
2 Q
When you prepared this document were therc 3
any numbers inserted at the beginning o'E paragraphs 4
on Page-1 other than the number l?
5 A
As.best I can recall, yes, there were.
~
I 6
Q Where did other numbers appear in the a
7 document as you prepared it?
S A
As best I can recall, thera would be a "2"
l 9
before " Misinterpretation" and a "3" before " Plant
(
10 design and operation."
l!-
i 11 Q
Did any,of.the remaining circle or hole
?
12 marks on this: document obliterate anything else in l
13 the original so far as you recall?
j 14 A
Not that I can tall, no, sir.
k l
15 Q
Had vital information required for an i
16 operator to make critical decisions to protect the j
17 reactor core been identified at any time prior to the 18 TMI-2. accident?
i 19 MR. WISE:
I-am going to obj ect to the i
20 '
question.
I think you are introducing an 21 uncertainty into the record that is not necessary g
i 22 at all.
f-23 I will permit him to answer it if he can 24 understand it.
25 MR. GLASSMAN:
I think the question is
['
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I L
e._
,,,__m l
1 LaBelle 180 clear.
2 MR. WISE:
If you want to make clear your 3
question it seems to me y'ou ought to either 4
+
?
tie it to what has been wr-tte,n here or ask him lt 5
6 the question in a general sense; that is my 7
-problem.
3 If you are tying it to what has been written in the document which you have shown to g
fl 10
'the witness, if you are asking him a question 2 '
l gi relating to that document, that is one thing.
i 12 If you are asking him some other question about " vital information," whatever that may l
13 14 mean to anybody,for.all time outside this
.15 document, that is another' question.
16 What my problem is is that I.am not sure l
17 which question it is you are asking the witness.
i l
f Is your question directed specifically at the 18 (Exhibib 'A27)
,19 particular sentence in GPU 2874 that you were I
20 examining about earlier or are you now asking t
l 21 some other question?
i I
[
22 MR. GLASSMAN:
My question is in general.
23 I think the question is.just a general question l
24 without regard'to the document as such and --
- fs_J 25 MR. WISE
Then I do have an objection i
.--a,.,
,,n-.---,,,_,
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1 LaBelle 181
+
j
('
~
2 based upon the fact that it seems to me that
\\
I 3
we have had no definition or foundation here j
4 for what is vital information in a general 15 sense.
..1 I
6 If you want to tie it to wh'at he i
I 7
specifically wrote in this exhibit, that is one l
8 thing; but if you are asking it in a general 9
sense, it seems to me vital information may 10 be very different to different people, and until i
11 we have some foundation --
12 MR. GLASSKAN:
I would be delighted to ask 13 that questiod.
I beli?ve Mr. LaBelle already I
14 testified that " vital" means'" vital."
15 MR. WISE:
He testified with respect to 16 specific questions.
You were asking about Exhibit ~llfI.
17 HNFh[ You have changed the question and have 18 gone into a new area, and I don't think the 19 questions are the same at all.
20 BY MR. GLASSMAN:
21 Q
Mr. LaBelle, what does the term " vital 22 information" mean to you as it relates to information 23 required for an operator to make a critical decision 24 to protect the reactor. core?
25 I would like you to please answer the k
i 182 1
LaRollo t
"A s
j 2
question without regard to this particular document.
A I think you have; answered your question by 3
4 stating that " vital information" is that information j
i which is requirad for the operator to,make critical i
6 decisions with respect to reactor core protection.
d if 7
Q-Had such'information been identified by i '
i w
l 8
Q i prior to the TMI-2 accident?
i 9
MR. WISE:
The question is had B & W 10 identified any information an operator n'oeded to p
i.
i.
j.
11 know before he,.could run the reactor-safely.
I I!
l 12 think this is getting, silly.
I i
13 MR. GLASSMAN:
I think the question s
1 14 atands on its own, Mr. Wise.
I don't t,hink you s
t 4
15 need to rephrase it.
t i
16 MR. WISE:
'It isn't a question of I
i f
17 rephrasing it.
It's a question of annoyance at 3
i 18 what appears to be a waste of time, Mr. Glassman.
t 19 To sit here at this stage in ~' this 4
20 litigation and talk,about whether B & W had ever I
21 given any.information to GPU that an operator 4
.h 22 needed to run the thing is silly.
We all knov f
23 that there was information given.
24 MR. GLASSMAN:
Th'ank you for your testimony, l
25 Mr. Wise, i
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i e
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e era
- v. $ ~
,w--e a--.mn.,-.-_..n,..,,, -,,.., _ _., _ _ _ _ _ _
7 1
LaBelle 183 N
MR. WISE:
It isn't testimony, Mr. Glassman.
2 You are wasting our time.
3 MR. GLASSMAN: If we get an answer to the 4
i N
5 question we can proceed and there won't be any i
6 more time wasted.
MR. WISE:
I don't understand what the 7
l
_8 question is.
9 Do you seriously have a question as to whether.%](]pprovidedinformationtoGPU?
Is 10 x
i 11 that what we are doing here this afternoon at c!,-
l 12 sixteen minutes past 12:00 into the eighth cn:
s 13 ninth deposition in this case?
-(
14 MR. GLASSMANs Mr. Wise, it is obvious
\\
15 this question is a predicate for a further 16 question and I.think we can have a simple yes p
17 or no answer.
18 We can put you on the stand.
I believe
[
19 Mr. LaBelle is the wit 4ess.
If he is as clear y
' 20 of the answer as you are, we will proceed and 21 not waste any tino.
It will take us one second g
.h 22 to get a yes or a no.
i l
23 MR. WISE:
I think I do have an interest 24 in protecting the record here and it seems to 25 me that we are introducing a lot of needless
's a
s e
~--
y 1
LaBelle 184 T
2 confusion into the record by questions that are 3
vague, broad and general in a way that does not 4
advance these proceedings one whit.
5 MR. GLASSMAN:
It,may.not advanceBCK]K's 6
position in the case, but we are entitled to i
l 7
find out whether it advances ours.
I h
8 MR. WISE:
You are not entitled to twist g
the record around and play word games in a way 10 that denies'information which everybody knows i
i j
11 is true.
12 MR. GLASSMAN:
If that is the case, then 13 let us have.the answer from the witness.
()
14 MR. WISE:
Why don't you repose the 15 question and let's try.and proceed, but I think 1
l 16 that really.this is stretching it quite a good 17 deal.
~
h d
18 I tried to be very lenient iftermsof 19
,, not presenting objections.,.but there are limits.
l
?
20 MR. GLASSMAN:
If it is as clear as you 21 say, Mr. Wise, we will have a yes or no answer 22 and we will proceed.
23 Will the reporter please repeat the pending I,
24 question?
(\\m/']
25 (The pending question was read. by the l
l 4
4
+, - - - -,.
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,----,--r
1 LaBelle 185
\\
2 reporter.)
~Y MR. GLASSMAN:
I wi3' rephrase the 3
4 question on the record.
BY MR. GLASSMAN:
5
[
6 Q
Mr. LaBelle,.was vital information which l
l was required for an operator to make critical decisions 7
8 to protect the reactor core identified by B & W 9
prior to the TMI-2 accident?
10 A
I would feel that the operator had been provided 1
l 11 with such information for core protection, yes, sir.
I 12 Q
Was there any., vital information of which 13 you were aware which was not provided to operators 14 prior to the TMI-2. accident and which would have 15 assisted the operator in making critical decisions to 16 Protect the' reactor core?
17 A
No, sir.
i 18 Q
Were the operators made aware prior to the i
19 TMI-2. accident of the possibility of a loss of coolant acciden(voch ginvolving increasing pressurization level
[
20 2
and decreasing pressure?
21
)
22 MR. WISE:
I object to that.
He can't 23 possibly answer that question.
24 MR. GLASSMAN:
Let us find out.
25 A
I do not know.
(}
4
---,,-v
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1 LaBelle 186 4
2 MR. WISE:
Yes.
You may ask him if he did I,
- i it, but to ask him what the operators knew 3
4 without establishing whether Mr. LaBelle met any l
s 5
Of them I think is a little silly.
ij 6
BY MR. GLASSMAN:
I 7
Q Mr. LaBelle, did (](]W provide its
{
8 customers with any,information concerning the possibility
[Ad6M) 9 of a loss of, coolant accidentA involving an increasing i
)
10 Pressurizer level.and decreasing pressure in the 4
4 11 pressurizer?
i
)
12 A
I do not know.
13 Q
If.you wanted to find out, who would you f'
14 ask?
15 A
For operating plants I would refer to our i
16 nuclear servicagdepartment.
17 Q
When you refer to the nuclear service department are you referring to the department now l
18 (6
{
19 designated as the customer service department?
3 f
20 A
I.believe so.
j 21 Q
Who in that department would you ask?
h 22 A
I don't know.
23 Q
The next full paragraph on GPU Exhibit-487 1Nh marked for identification, which is preceded by
(
24 r
25 the item or by the number "2" according to your 4
J
1 LaBelle 187 N
2 testimony.as the document was originally prepared,
)
1 J
I' 3
reads as follows:
4
" Misinterpretation of past operating 5
- Xperiences resulted in continuation of plant i
6 operation with a component which possessed a i
7 high f ailure potential. "
8 Whose misinterpretation of past operating 9
experiences were you referring to in this memorandum?
10 A
This was my personal conclusion that there had I
j 11 been past operating experiences which had not been l
12 integrated to the point that failure potential had f
13 been assessed properly.
()
14 MR. GLASSMAN:
Will you read back the 15 answer to me, please?
16 (The record was read by the reporter as 17 requested.)
18 BY MR. GLASSMAN:
19 Q
What past operating experiences are you j
20 referring to?
21 A
As best I can recall this was based on the 22 failure of the PORV, the PORV operation.
23 Q
What failure of the PORV operation are you 24 referring to?
25 A
During the TMI-2 incident.
g-g 1
w w --
1 LaBelle 188 2
Q What operating experiences prior to the 3
TMI-2 incident were you referring to in this paragraph?
4 A
The one that I recall was the one at Davis-5 Besse.
i 6
Q When did that occur?
7 A
I do not know.
8 Q
But it was prior to the TMI-2 accident; 9
is that correct?
10 A
As best I can recall, yes, sir.
11 Q
In what respect had the operating 12 experience involving the PORV at Davis-Besse been 13 misinterpreted?
14 A
Not referring specific.lly to Davis-Besse but 15 to the potential for failure of.a component such as 16 the -- the component operation such as the PORV should 17 hold some significance if it occurs more than one time.
18 Q
Had the PORV failed more than one time on B()[Wdesignedplantspriorto the TMI-2 accident?
19 i
20 A
I could'not say with assurety that the PORV l
21 itself had failed.
I would recall that there had been
_h 22 operating situations where the PORV had been open 23 during operation.
24 Q
Do you recall that there were situations 25 prior to the TMI-2 accident in which the PORV had
- O I
L
I LaBelle 189
("
2 opened and had failed to close as it was designed to D]
3 dO7 4
A Not that I could state with assurety, no, sir.
5 Q
Was it your understanding when you prepared
}
(Exhibib-M7)
.l 6
Exhibit GPU 2874 that such events had occurred?
i 7
A It was my, understanding that the PORV operation 8
needed to be further examined.
9 Q
Were you aware of a stuck-open PORV (76~0000) 10 occurrence at the Oconee plant in 197qp 4
5 11 A
I do not recall that.the PORV was stuck open or 12 the specific date of,the incident that you have 13 described.
I have some recollection of a PORV f
f 14 operation concern at Oconee.
15 Q
what was the basis of your conclusion that 16 past operating experience with PORV prior to the TMI-2 17 accident had not been integrated to the point that l
18 failure of the PORV had been assessed properly by l
10 5)T)"?
20 THE WITNESS:
Could you. repeat that 21 question, please?
(
22 (The pending question was read by the j.!
23 reporter.)
l l
24 A
My recommendation here had no particplar basis l
l l
25 nor would I like for it to imply that B & W had not I
s i
I.
y.
,.-,,,_______.,_,__.___y.
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LaBelle 190 i
/~'N 2
followed a proper course of review following any U
3 earlier events surrounding PORV operation, but that 4
in the follow-on operation of BA]W plants that it 5
would certainly be worthwhile to continue to look for 6
events which were recurrent and their importance.
7 Q
The second full paragraph on GPU Exhibit-N83 8
la uses the past tense when it says " Misinterpretation 9
of past operating experiences results" I add 10 emphasis to "resulted" "in continuation of plant 11 operations with a component which possessed" and l
12 underscore, I emphasize the word " possessed"
--A 13 high failure potential."
14 Is that correct?
15 MR. WISE:
That is what that says.
You 16 have read that properly.
Do you have a 17 question for the witness?
18 BY MR. GLASSMAN:
19 Q
Is that correct, Mr, LaBelle?
20 MR. WISE:
I object uo that.
This is 21 harassing him.
Let us get on with the h
22 examination.
23 MR. GLASSMAN:
I don't think it is 24 harassing at all, Mr. Wise.
The document speaks eg 25 in the past tense and the witness is attempting I
n _
1 LaBelle 191 to characterize this document as purely 2
speaking in the future tense.
3 There seems to be an inconsistency.
I j
4 would like to make it clear that this deals with 5
i 6
the past tense, r
i 7
MR. WISE:
I don't think that is a fair 8
characterization of what Mr. LaBelle had to i
say.nor do I think that is the proper way to g
i 10 continue and advance this deposition.
i
.I j
11 If you have questions of the witness you l
12 may pose them.
To read something to him and 13 ask him to correct your reading seems to me a O)
(,
14 waste of. time.
15 MR. GLASSMAN:
As long as we all agree it 16 refers to the past tense.
i 17 MR. WISE:
What refers to the past tense?
i 18 We can all agree what this document says.
You j
19 have read it.
We have all read it.
s' 20 BY MR. GLASSMAN:
h 21 Q
What operating experiences prior to the
.h 22 TMI-2 accident had been misinterpreted?
23 MR. WISE:
Hasn ' t that question already 4
24 been asked and answered?
I thought we did this (5thIhNN h
)
25 about five minutesgago.
We had testimony about T
t
- -...,., _. -. -., -.,,,.. - - -. - - ~. - -. _... - -. - _.. -.. _ -. -.,.,. -. -.. -. -. - -. -.
e-1 LaBelle 192 t
2 PORV failures and there was quite a good deal 3
of discussion about tFat.
4 MR. GLASSMAN:
We will accept that, Mr.
t I
5 Wise, and we will go on.
i 6
BY MR. GLT 79 MAN l
l 7
Q' Mr. LaBelle, were there any past operating 8
experiences other than PORV failures which had been 9
misinterpreted prior to the TMI-2 accident and 10 resulted in continuation of plant operation with a 11 component which possessed a high failure potential?
i 12 A
Not that I am aware of.
I l
13 ',
Q Had past operating experience with respect 14 to PORV been integrated by.q[%]W to the point that l
l 15 failure of the PORV had been assessed properly before l
16 the TMI-2 accident?
l 17 A
It had been assessed and I don't think I could i
h 18 offer anything further to that.
i 19 Q
Had it been assessed properly?
i
.~
20 A
Who can define what " properly" is?
i.
l 21 Q
What do you mean by the term " properly" as 22 used in your previous testimony?
(too-pemenA i
23 A
With one hundred percentAprobability of i
l 24 successful resolution.
i 25 Q
Who within B & F had assessed the 7
s l
-e.
--y
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e s-.
s 1
LaBelle 193 T
likelihood of. failure of.the PORV prior to the TMI-2 2
accident?
3 A
I do not know.
i 4
s 5
g Do you know what unit made such.an assessment?
l 6
I A
I do not know.
7 i
8 Q
Do you know if.any, person or unit within q[k[%madeanassessment of.the likel-ihood of failure 9
,i 10 of the PORV prior to the TMI-2 accident?
I!
11 A
I do not know.
i l
12 Q
If you wanted to find out, who would you 13 ask?
A I just would not know.
i g4 15 Q
The next sentence in GPU Exhibit-474 i
16 marked for identification reads as follows:
17
" Focus shifted too much to plant 18 operation / availability rather than overall P ant safety and equipment reliability."
l 19 l
20 What did you mean by the term " availability" 21 as used in that sentence?
22 A
The period of time for which the plant is in l
23 operation versus the period of time for which the i
24 plant could have been in operation.
I 25 Q
Prior to the TMI-I accident was the focus 4
f
1 LaBelle 194 2
shifted too much to plant operation / availability
'O 3
rather than overall plant safety and equipment 4
reliability?
5 THE WITNESS:
Could you please repeat that i
6 question.
I didn't hear the first part of it.
I' (The pending question was read by the 7
g reporter.)
g A
Not that I am aware of.
Mw. recommendation here 10 is focusing on further review of. equipment maintenance i
1 11 versus equipment reliability.
12 Q
Prior to the TMI-2 accident was $[(3N 13 focus in any. respect directed towards equipment
()
14 maintenance rather than equipment reliability?
15 A
There is an emphasis on maintenance of equipment (WY (0.&
16 through our nucleargor customer serviceAdepartment.
17 Q
Why is there an emphasis on maintenance 18 of equipment rather than equipment reliability?
19 A
My recommendation here is one of utilizing 20 the maintenance history more 'to further examine the 21 reliability of components that were being maintained 22 or replaced.
23 MR. GLASSMAN:
I would like to have the 24 question repeated and I would like you to answer l
25 the question, Mr. LaBelle, without regard to your
g,_
s-
_t-1 LaBelle 195 2
recommendation in this document.
N (The question referred to was read by the 3
s 4
i reporter as requested.)
A This is co.tsistent with the design for operat.4,n 5
6 of the plants to the best of my knowledge.
MR. GLASSMAN:
Can you read that back, I
7 i
l P ease?
8 9
(The record was read by the reporter as 10 requested.)
11 BY MR. GLASSMAN:
12 Q
Was this consistent with'the design for 13 operation of the plants prior to the TMI-2 accident?
14 MR. WISE:
Was what consistent?
You know, 4
15 I have a real problem with proceeding this way i
16 with these continual jaunts into vague, i
17 ambiguous sorts of th. fugs, questions that i
18 contain. as their subjects words like "this" i
i 19 and "that" and "such" and so on.
It just makes 20 it very, difficult to know where we are in the i
j 21 record.
h 22 MR. GLASSMAN:
I guess with all due 23 respect, Mr. Wise, maybe my memory of the prior 24 question is better than yours.
i 25 MR. WISE:
I would be willing to concede f
l i
i
I LaBelle 196 2
that happily, but in terms of being able to follow, I wish you would give me a little 3
4 consideration and I tend to be a little slow i
b sometimes with these things I know, but if you i
6 could just spell out.in each question to some il 7
extent what it is you are asking, it would F
8 certainly, help me in trying to follow along i
9 here.
!t 10 MR. GLASSMAN:
I will try, Mr. Wise.
I 1
11 will gladly be of assistance to you.
4 j
12 MR. WISE:
Thank you.
13 BY MR. GLASSMAN:
, ()
14 Q
Mr. LaBelle, prior to the TMI-2 accident i
thereanemphasisat.B[)[Nou maintenance of 15 was 16 equipment rather than on equipment reliability?
17 A
In a general sense that was my opinion.
(
18 Q
What was the basis of your opinion?
I 19 A
Just that it was an opinion.
I 20 Q
Was that based on your experience at 21 B s W7 3
g l
7 22 A
Yes, sir.
1
{
23 Q
Was the emphasis at B sW on maintenance 24 of equipment rather than equipment reliability prior
[
25 to the TMI-2 accident as you understood it consistent nU I
l 1
LaBello 197 2
with the design for operat, ion of the equipment prior to the TMI-2 accident?
3 THE WITNESS:
Could you repeat that one 4
5 again, please?
6 (The pending question was read by,the re' porter.)
7 8
A The maintenance and reliability supporting the designof%)()Nsuppliedequipmentwasconsistent 9
10 with design -
.the design. basis in effect prior to 11 the TMI-2 incident.
k 12 Q
When you refer to the design basis for the 13 equipment as in your last answer, are you referring 14 to design basis for the equipment provided by B & W7 15 A
Yes, sir.
I would qualify that by,saying as 16 Provided by B & W and as licensed with the. Nuclear 17 Regulatory.Commissio 8
MR. WISE:
Off the record.
.19 (Discussion off the record.)
20 BY MR. GLASSMAN:
21 Q
Mr. LaBelle, in the next indented paragraph
.k 22 on GPU Exhibit-287 under the, heading " Action" there l
23 are initials DRB which appear in that paragraph.
Can 24 you tell us what that refers to?
25 A
DRB refers to Design Review Board.
gs 4
L_
1 LaBelle 198 7(,)
2 Q
On the next line at the very end of the 3
line there are the letter "R" and the letter "D."
4 Does that correctly. refer to R & D?
My copy is not d'
5 quite legible.
6 A
R &
D, Research and D(/elo,, ment.
7 MR. GLASSMAN:
I think this is a good time l
{
8 to break for lunch.
l 9
(Whereupon, at 12:52 o' clock p.m.,
a i
10 luncheon recess was taken.)
11 12 13
,m
(
14 15 16 17 AFTERNOON SESSION 18 2:18 P.M.
19 DANN Y W.
L aB E L LE resumed 20 as a witness and, having been previously duly i
21 sworn, was examined and testified further as I
22 follows:
l 23 EXAMINATION (Continued) l 24 BY MR. GLASSMAN:
O t.
j 25 Q
Mr. LaBelle, in the second indented v
l E
~
e--'_~_---
1 LaDollo 199 fh()
2 Paragraph under the heading " Action" there is a 3
sentence which reads as follows, referring to the 4
last sentence of.that paragraph:
~
5 "We should not be restrained from i
t i
6 hardware backfit."
7 What is meant by.the term " hardware 8
backfit."?
9 A
I think the reference here is to hardware 10 improvements being made on operating plants.
11 Q
What does the word "we" refer to in that 1
12 sentence?
((Ed) 13 A
As best I can recall,. Babcock & Wilco 5, O
]
14 Q
Was Babcock & Wilcox in any.way. restrained 15 from bardware backfit in the period prior to the 16 TMI-2 accident?
17 A
I think here you have to view this in a general 18 environment in which there are many recommendations 19 for hardware, operational or other improvements that 20 could be suggested by Babcock & Wilcox or any other 21 firm that is attempting to sell equipment or services 1
22 and that not all of those recommendations are accepted l
23 or purchased by a customer.
24 Q
With that background in mind, can you tell
()
25 us whether in the period before the TMI-2 accident
?
l
1 LaBelle 200 (pt)
Babcock & Wilcoxgwas restrained in any manner from 2
hardware backfit?
3 A
Not that I could say in the strictest sense, no, 4
sir, other than the fact that there were improvements 5
i r suggestions or recommendations that were not sold i
6 f
to our customers.
7 8
Q Were there improvements, suggestions or recommendations that were not sold to %]()Kcustomers j
g because of any. restraints.from hardware backfit?
10 3 I 11 A
In the same context as I have mentioned e
12 Previously, not that I am aware of.
13 Q
What did you mean by the word " restrained" 1 ()
14 in this sentence?
15 A
As best I can recall just in looking at the l
16 wording that is provided here, that of continuing to
]
17 look at operating experience, component reliability, P ant operations which may be of continued benefit and l
i 18 19 understanding for our customers.
20 Q
Was there a full-time organization within 21 B& W prior to the TMI-2 accident which was devoted to 22 Operating experience?
i 23 A
Not that I can recall m a full-time service i
24 that a customer had purchased, no, sir.
25 Q
Was there a full-time service devoted to f-wg j Q
~
1 LaBelle 201 m
k,,)
2 operating experience that was offered to customers l
3 prior to the TMI-2 accident?
i 4
A I have no knowledge of that type of area, no, 5
sir.
f 6
Q The next paragratih of GPU Exhibit-474
/
7 marked for identification reads as follows:
l 8
" Plant design and operation has been too i
9 rigidly. based upon conservative techniques and 10 supported by,a design bases which contain 11 highly. limited analytical work scope."
1 12 What is meant by,the term " conservative 4
l l
p 13 techniques"?
a i
14 A
Well, conservative technique is a phrase that 15 says that it is a conservative technique.
16 I don't understand your question.
l 17 Q
In what respe_ct are techniques conservative?
?
i fhose techniques are t
18 A
Just by assumptions that 19
' based on and the input;used in-those techniques.
4 i
20 Q
Were conservative techniques used by I
21 B(h[NinpreparingtheSARs?
l 22 A
In the context of the accident analysis i
(
23 submitted in the Safety Analysis Reports, yes, sir.
i l
24 Q
In what respect did the design basis for 25 plant design and operation contain highly limited t
n 1
LaBelle 202 2
analytical work scope, with particular emphasis on the O
3 word or words " highly. limited"?
4 A
I think to put the ent ire caragraph into
{
5 perspective for you, that the paragraph deals with t
6 analyses that have been provided for the licensing of 1
7 plants'via the accident analysis in the Safety Analysis Shh 8
Report and that would be beneficial to the nuclear 9
industry to have additional. analytical work done to 10 continue to improve upon the understanding of plant j
11 operation.
12 Q
In what respect was the analytical work 13 scope highly. limited?
14 MR. WISE:
I think he just answered that 15 question.
16 BY MR. GLASSMAN:
17 Q
Mr. LaBelle, what were the limitations upon
~
18 the work scope of the SAR's?
19 A
The limitations are the results of the work that 20
.is presented in the accident analysis of the Safety 21 Analysis Report.
22 Q
Aside from theslimited results, what did 23 you mean by " limited analytical work scope"?
24 A
Limited work scope is a part of the results of O
25 the accident analysis which was' referred to previously
1 LnBollo 203 l
A0 2
for the Safety Analysis Reporg.
s 3
Q
.What did you mean by the term " work scope"?
i 4
A Work scope is the -- is just what it says, the l
5 scope of the work presented in the Safety Analysis 1
6 Report, accident analysis.
1 7
Q Following the TMI-2 accident did you learn 8
that additional analytical work beyond that performed for the SAR's would be beneficial to the nuclear 9
10 industry?.
k 11 MR. WISE:
I will object to the form of 12 the question.
The witness can have a try at 13 answering that if he desires.
14 THE WITNESS:
Would you repeat the 15 question, please?
16 (The pending question was read by the 17 reporter.)
18 A
I believe in a general sense that analysis 19 following the TMI-2 incident which would. be helpful 20 in understanding the events which occurred or which 21 may.be of help to the industry in furthering the g
l 22 understanding of other events would be helpful to the l
23 nuclear industry.
I will qualify that by saying "but 24 not necessary."
()
25 Q
Are there any other qualifications you
2 __..
.w--
n l
1 LcBollo 204 2
would like to make?
A No, sir.
3 I
4 Q
I would like you to refer to Page-4 o f.
5 GPU Exhibit-287 marked for identification.
Will you 6
tell us what you were referring to by.the words 7
"best estimata techniques" in the first sentence on 8
Page 27 9
A Best estimate in the context used here would be 10 referring to as close to actual as possible.
I 11 Q
How would that differ from bounding i
12 techniques?
13 A
Bounding techniques in the context used here 14 would be referring.to trying to provide a conservative 15 response in any.one or all results of the technique.
t.!
}
16 Q
After the number "4" on that same document 17 there is a sentence which reads:
18 "The analytical and hardware designers i
19 have become too separated from actual plant 20 operation response to transient conditions at 21 sites."
22 What were you referring to when you were-l l
23 referring to analytical and hardware designers?
24 A
To put this into the proper context, I would b\\
(,j 25 note that the analytical and hardware design ~ staff of
w.
_ w _ _ -_
1 LaBelle 205 an engineering department such as the Babcock &
p/
(grnD 2
WilcoxAcompany would be operating in an atmosphere s-3 of continuing business involvement with development 4
j and sale of our products and services -- of their
.l 5
s
.i products and services, and as such are not limited to
' l 6
servicing plants that are in operation.
7 l
Q Had the analytical and hardware designers 8
at Babcock & Wilcox become too separated from actual I
9 i
plant operation response to transient conditions at 2
10 lI sites prior to the TMI-2 accident?
11 A
In the context of the previous explanation, yes, 12 sir.
[yfegg) 13 (g)
Q Under Item No.-5 on Page-2 of GPU Exhibit-27/
t g
14
$7hImarked for identification, under the heading 15
" Action," there is a sentence that reads as follows:
16
" Design philosoppy should tend to minimize 17 the need for operator intsrvention during any 18 transient operating mode until such time as 19
~;
event can be diagnosed properly and appropriate 20 l
actions taken."
21 g
Have I properly read your handwriting, 22 Mr. LaBelle?
23 A
Yes, sir.
i 24
()
Q Did you discuss in words or substance this 25 l
l
)
1.
1 LaBelle 206 i
$[h[W7 2
statement with anyone at O
3 A
Not that I can recall.
4 Q
When you prepared this statement did you i:
5 have any.particular type of operator intervention
- i 6
in mind?
7 A
No, sir.
8 Q
Were you at this time aware that the 9
operators at TMI-2,had intervened to terminate the (lh high pressure injection}A uring the course of 10 d
the day?
4 4
j.
11 THE WITNESS:
Will you repeat the question, b
12 please?
13 A
If you are referring here"to the TMI incident (190b2D 14 of March the 28th, 1979p I would say that I had an j
15 awareness of operator involvemer t during the event i
16 sequence and that may.have been a part of the basis 17 for my. recommendation.
18 Q
Were you aware of the design of.any other 19 nuclear plant which involved the minimization of a need i
20 for operator intervention during a transient operating j
21 mode until such time as the event could be diagnosed l
22 properly and appropriate action taken?
f 23 A
Yes, sir.
i 24 Q
Can you tell us what you were aware of in 25 that regard?
4 t
)
ll 1
LaDollo 207 4
We have a -- BC5(K has a German contract with 2
A (f0 Brown Boveri Reaktoraterwhich part of the design basis 3
4 prescribes the minimization of operator actions 1
5 during transients until such time as they can be
>l I
6 properly. diagnosed.
f 7
Q Who Provided the design basis for that i
8 plant?
9 A
The German government.
10 Q
Did B & W design the plant to satisfy
~
i I
11 those requirements?
I a
.i 12 MR. WISE:
Did B & W design the plant.
13 I object to that question.
It is contrary to j
( j/
14 the facts which have been established in this 1
15 case.
16 BY MR. GLASSMAN:
i 17 Q
Do you know what.the proscriptions on an
[HPI) 18 operator action with respect to high pressure injectionj f
(N~
{
19 are on the MK plant?
4 i
20 A
I do not understand what you mean by proscription.
i t
~
21 Q
Is the operator on the MK plant permitted i
to terminate high pressure injection during a transient l'
22 23 operating mode before the esent :ould be diagnosed 24 properly and appropriate action taken?
l([)
23 A
I do noe know.
4
c.
1 LcGollo 208
~'
2 Q
Do you know if the operator on the MK P ant is permitted to terminate high pressure l
3 injection (A uring
(.go-minoles) gp.0 d
the first thirty, minutes 4of.a 4
i 5
+
i 6
A Let me state for the record that I am aware of 1
7 a time limit criteria that is used in the German 8
licensing, but I do not know the exceptions that 9
could be taken from that requirement.
10 Q
Are you referring to a time limit criteria I
11 on operator termination of high pressure injection?
12 A
I am referring to a general time limit criterion.
13 Q
Are you referring to a general time limit 14 criteria for operator action following a transient?
15 A
Yes, sir.
16 Q
When did you first become aware of such 17 time limit criteria?
18 A
I do not-know.
19 Q
But before the TMI-2 accident?
20 A
Yes.
21 Q
APProximately how long before the TMI-2 22 accident did you become aware of such time limit
}
23 criteria?
24 A
I do not know.
25 Q
How did you become aware of such time EEe n
m
~
l 1
LcBolle 209 2
limit criteria?
3 Through general consultation, technical A
4 consultation, with my. counterpart at Brown Boveri (Bod 5
Reaktorateg ll 6
Q Who was your counterpart at Brown Boveri 4
7 Reaktorate?
8 A
At that time it would have been Mr. Caspar.
.# Do yo.u know Mr. Caspar's position at BBR7 9
Q 10 A
I do not know his current position, no, sir.
(I,'
11 Q
Do you know,what his position was for the II 9
4 12 entire period prior to the TMI-2 accident?
13 A
I do not know his specific organizational name.
14 It would have been the counterpart of the Safety i
15 Analysis Unit.
16 Q
Do you know if there was an additional l
17 person at BBR who was the counterpart of the ECCS Unit?
18 A
Yes, sir.
i 19 Q
who was that?
l 20 A
I do not recall.
21 Q
During the period prior to the TMI-2 g
22 accident how frequently did you have technical f
l 23 consultations with Mr. Caspar.?
a l
24 A
Only as requested.
)
25 Q
And requested by whom?
u_
~
_ w,n 1
4 1
LaBello 210
~T.
2 A
Mr. Caspar.
,s (A}
i x/
),
i 3
Q Did anyone elacs request you to,consu;1t t
i
^
j 4
_with Mr. Caspar?
s say} that 'that did'not happen.
5 A
I c uld riot t
i 6
Q Did Dr. Womack ever request you to consult i
7 with Mr. Caspar?
8 A
I do' not know.
'~
si
(~
\\
g Q
For what urpose did you consult with 'Mr.
10 Caspar.before the TMI-2 accident?,
i 11 A
I think to put this into the prope,r t. cor. text, thdt h(Ah '
12 Babcock & WilcoxjCompany was in a position of selling g
i g
13 technical consulting sorrices to the Brown;Boveri I'
h$g.)
.)
and my involvement with 14 ReaktorategCompany in Germanyg r
15 them would h'avo. been to thb extent that my services s'
l-1 a
16 were sold to them or my.organiz,ation.
17 Q
Will you' describe fcr us the services of 18 you or your organization that were sold to Babcock'.
1
!s 19 Brown Boveri?
20 MR. WISE:
Did you say " Babcock Brown h
21 Boveri"?
}-
k, J
22 MR. GLASSMAN:. I'm sorry.
I will withdraw
(
i 23 that.
24 BY MR. GLASSMAN:
)
25 g
We will call it,BBR, Brown Doveri 4
L-
1 LaBelle 211
~-
, g' Q 2
Reaktorate.
r Q=,-
x 3
A Not specifically, I could not.
s'
.s v
4' Q
Can you describe them for us generally?
l-5 A
since they.were a counterpart of the safety l
I 6
Analysis Unit in terns of.the contact I would have had 9
~
7 with the BBR organization we could have provided a 8
variety.of services in that particular Safety Analysis
{
9 Unit's operation, i
10 Q
Did you maintain any. file with regard to I
11 the services you provided?
d 12 A
There may.be such a file.
13, Q
If.there was such a file where would it be?
j 14'-
A This would be in my personal chron file.
(&@
15 Q
Did Babcock & Wilcox'sA Safety Anal { sis Unit (Al-K)
MK plant?
16 perform safety analysis for BBR for the A
17 A
We would have assisted BBR in performance of 18 safety analysis, but I could not attest to what those 19 particular areas would be.
20 Q
Did you assist BBR in safety analysis 21 for the MK plant in the period prior to the TMI-2 i
03 alb 22 accident of. March 28th, 197 ?
23 A
To the best of my recollection, yes.
24 Q
Was such safety. analysis at that time 25 based on German licensing requirements?
e t
.a y,
L 1
LOBollo 212 2
A Yes, sir.
t
\\-)
3 Q
Did the ECCS Unit perform any. analyses
()U-Eb 4
for BBR for the MKaplant in the period prior to the i
5 TMI-2 accident?
6 A
I do not know.
7 Q
Did you mention or discuss German i
8 licensing requirements with anyone at BCq]W at any time D903M) 9 prior to the TMI-2. accident on March 28th, 1979?
4 I
10 A
Not that I recall,_
it could have happened.
but l
11 Q
Did you make any notes or prepare any i
12 documents whatsoever relating to German licensing i
13 requirements prior to the TMI-2 accident?
(_.,)
14 A
I don't know.
15 Q
If.you made such notes or prepared such 16 documents, where would they be found?
17 A
If they still exist, they should be in my BBR 18 personal chron file.
19 Q
Do you have any. reason to believe that 20 such documents once existed but no longer exist?
21 A
It'was a long time ago.
I just do not know.
i 22 Q
Approximately how long ago was this work i
23 done?
I 94 A
I don't know.
li
,/
w.-)
25 Q
Do you recall the approximate years?
s I
L I
L 1
LaBolle 213 2
A It was just too long ago.
(
3 Q
Prior to the TMI-2 accident did you consult 4
with,anyone other than Mr. Caspar from BBR?
5 A
Could you explain what you mean by " consult."?
I 6
Q We can be more general than that, Mr.
7 LaBelle.
I will rephrase the question.
8 Prior to the TMI-2 accident of March 28th, (190nd 1979 did you meet with or have any discussions with 9
A 10 any persons from BBR other than Mr. Caspar?
11 A
It is certainly possible.
12 Q
Do you recall any other persons with whom 13 you met or spoke?
ID) 14 A
No, sir.
15 Q
Did you discuss with Mr. Caspar or anyone 16 elce at BBR any aspects of the Davis-Besse transients 17 which occurred in 19777 18 A
Not that I can recall.
19 Q
Did you go to Germany at any time prior to 20 the TMI-2 accident?
21
.A Yes.
22 Q
What was the purpose of your going to 23 Germany?
24 A
I do not recall.
25 Q
Did you go there on business?
j
c- ---
n 1
~
LaBelle 214 9
2 A
Yes, sir.
O 3
Q Did you visit with people at BBR7
{
4 A
Yes, sir.
1 5
Q Do you recall when you went?
I 6
A No, sir.
I 7'
Q Did yon bring.any written materials with 8
you at that time?
9 A
I do not recall.
10 Q
Did you keep any records of any visits I
11 you made to Germany?
12 A
I could have.
13 Q
Do you recall any such records?
14 A
No.
15 Q
If you did maintain such records where 16 would they be?
17 A
They would be in my personal BBR chron file.
18 Q
What period of time is covered by your 19 personal.BBR chron file?
20 A
I do not know.
21 Q
Does it cover the period subsequent to 22 the TMI-2 accident?
23 A
It should.
24 Q
What is the basis of your statement that 25 it should cover the period after the TMI-2 accident?
m w...
1 LaBelle 215 2
A I have no recollection of what materials I 3
may have kept relating to.the BbR contract following 4
the Three Mile Island inciden ti Prior to the TMI-2 accident were you 5
Q 6
familiar with any.other differences in design between (M-X) the MK plant and'other.B Z W designed plants?"
7 3
8 MR. WISE:
Any.other.than what?
9 MR. GLASSMAN:
Any plants other than the l
10 MK plant..
?
a i'
11 MR. WISE:
Can I have the question read 3
12 back?
Maybe I missed something.
J I
13 MR. GLASSMAN:
Maybe you.didn't.
14 (The pending question was read by the 15 reporter.)
$VMber-l) 16 MR. WISE:
Number one there is no predicate g
i 17 for the question that I heard.
18 MR. GLASSMAN:
I will rephrase the question.
19 BY MR. GLASSMAN:
20 Q
Mr. LaBelle, prior to the TMI-2 accident i
21 were you familiar with any differ.ences in design 22 between the MK plant and the B & W 20571 ants ?
23
'A I think first off you have to put into 24 perspective the fact that the Muelheim-Kaerlich plant h
bd 25 was designed by the Brown Boveri Reaktorategorganization
m '
r-v l
LaBelle 216 1
based upon the 205 -fuel assembly ; design plant that 2
O B^M offers domestically,and there could be design 3
differences that exist.
I am not aware of all of 4
those design differences.
5 I
Q Are y u familiar with an autgmatic PORV 6
\\
(1:1-l</
block val've closing f.eature of the MK plant?
g 7..
8 A.
I am aware that it is a consideration, Q
What do you mean by.the term " consideration"?
g A
It is a design consideration.
To the best of 10 i,
my. knowledge, that.has not been finalized.
gg 12 Q
Could you describe for us the design consideration for automatic closure of the PORV. block 13 valve as you understand it?
14 A
No, I could not.
15 16 Q
When did you first become aware of this design consideration?
17 18 A
I'do not recall.a specific time.
19 Q
Did you.become aware of it before the (1003b?8)
TMI-2 accident of. March 28th, 1979?
4 20 A
No, sir.
21 22 Q
Do you know if such a design feature involving automatic closure of the PORV block valve 23 has ever been offered to an American plant?
24 O
V 25 A
No, sir.
1
e 1
LaBelle 217 1
2 Q
Did you at any time see any documents
~
s_s/
{
3 Prepared by,other plant design unit managers 4
relating to lessons learned or potential lessons to 5
be' learned?
6 A
Not that I can recall.
7 Q
Do you know whether any other plant 8
design unit managers ever prepa.ed such documents?
9 A
No, sir.
10 MR. GLASSMAN:
Off the record.
l 11 (Discussion off.the record.)
12 (Recess taken.)
13 MR. GLASSMAN:
I would like to have marked O
14 as GPU Exhibit-288 for identification a four-h-$1ge)
(194g56) 15 Page4 document dated April'30th, 1979Afrom Mr.
16 LaBelle to Mr. Roy;
Subject:
Response to (i17-FA-PLAMTb 17 Q'uestions on LOFW for 177 and 205-FA-Plants.
4 l
18 (document dated April'30th, 1979 to Mr.
~
19 Roy from Mr. Labelle, consisting of four pages, was marked as GPU Exhibit Eb)-288 for 20 (Flo603) 21
. identification as of this date.)4 22 BY MR. GLASSMAN:
l 23 Q
Mr. LaBelle, I sh'ow you what has been 24 marked as GPU Exhibit 288 for identification (handing O
25 document to the witness).
Did you send that document t
-~
m_
- - - ~ - -
_m-1 LaBelle 218 2
to Mr. Roy,in the ordinary. course of business?
\\'
A It says that I did, so I must have.
3 4
Q Does your signature appear at the end of i
the last page?
5 l
6 A
Yes, sir.
7 Q'
There is a reference on GPU Exhibit-288 8
marked for identification to"D.
H.
Roy to E.
A.
- Womack,
(/77-FA.-plants) 9 Analysis of.LOMFW flow for 177gand 205-FA plants, h90'lO5) 10 April 5, 1979g" j
ill 11 I show you what has previously been i
12 marked as GPU Exhibit-40 for identification and ask you l
13 if_that is the document to "hich you were referring 14 in GPU Exhibit 288 (handing document to the witness).
l 15 A
I could not say.with any.assurety that it is.
16 Q
Do you know of any other document that i
17 would fit the description on the reference line to 9
18 GPU Exhibit-288?
19 A
Not that I recall.
20 Q
Did you prepare Exhibit GPU Exhibit-275 at 21 the request of Dr. Womack?
22 A
I do not know.
l 23 Q
Do you know what caused you to prepare
[
24 GSU Exhibit 288?
25 A
Not a cause that I can recall.
4 l
,.. _ _. _..... _. -. _. _.. ~. _
.y,
_W u-
--e-.
--m 1
LaBelle 219 i
2 Q
Did Dr. Roy request you to prepare a O
3 response?
i 4
A Not that I can recall.
f 5
Q Have you ever seen a copy,of GPU Exhibit ~'/d l
4d 'at any. time in the past?
6 7
A I 3ust do-not recall.
8 Q
Do you recall receiving any document 9
raising questions such as or similar to those_ contained i
);
10 in GPU Exhibit.407
)!
l 11 A
I do not recall, although Exhibit-G88 states that 12 this particular exhibit-contains responses to several j
13 questions which have bee: raised in the referenced j
14 memo.
l 15 Q
I would like you to review GPU Exhibit-AST 16 24 marked for identification and just tell us whether 17 you discussed any of the questions or responses B[&['
i 18 contained in this exhibit with anyone else at 19 A
I have no recollections of having discussed i
)
20 these items with others within B.& W.
5 4
21 Q
The first par'ag;aph of GPU Exhibit-275 22 refers to responses" based on analytical results 23 obtained for the most part from CADDS simulation l
l 24
- studies of the TMI-2 event."
(~/
25 Were those studies done within the Safety l
I-
. ~.
,,,_---.,-.,,_.-,-._m,,
,, -.,,. - = -,.,..
?
1 LaBello 220 1
- i 2
Analysis Unit?
3 A
Yes, sir.
4 Q
Do you know who performed those studies?
I
- {,
5 A
Yes, sir.
I 6
Q Who performed those studies?
7 A
Mr.' C.
S..Banwarth, B-a-n-w-a-r-t-h.
That 8
could be a w-o.,.but I think it is w-a-r-t-h.
i 9
Q Did.anyone else perform those studies?
10 A
You are referring here to~CADDS-type studies?
I j
11 Q
Yes.,
I j
12 A
There could ha've been others.
3 13 Q
Did you supervise the CADDS simulation O) i t'--
14 studies which are referred to in this document?
15 A
I would have, yes, sir.
i 16 Q
What other studies were made in the course
[
17 of preparing the responses in this document?
i 18 A
What do you mean by "what other studies"?
19 Q
Thesentenceyouweregust referring to 20 reads:
21 "The responses are based on analytical f
22 r e sult s. obtain ed,- f o r. -th e mo s t par t, from CADDS f'
23 simulation studies of the TMI-2 event."
24 What did you mean by the words "for the s
25 most part"?
i i
I i
i e
1 LaColle 221 A
As best I can recall, not all of the questions 2
n%/
uld be responded to with information provided by 3
the Safety. Analysis Unit through the CADDS simulation 4
- j studies.
5 6 -
Q What questions could not be responded to through the CADDS simulation studies?
+
7 8
A Okay.
To the best of my. knowledge, at least GJeS}Tdn k @ XSNEsn-8) (Qmpf7bn-7) 9 Questionr3,j4 and.6 and 7 could not have been 4
a 10 completely responded to by. safety.anaIysis.
11 Q
What are the. basis of the responses to 12 Questions ~3, 4,
6 and 77 13 A
I am not sure what I rnderstand by " basis."
14 Q
How did you formulate a response to 15 Questions 3, 4,.6 and 77 16 A
I have no recollection.
17 Q
Was there any. input to these re'sponses; 5
18 from the ECCS Unit?
19 A
From the response and the question / ittwould 20 appear that there was some input provided by the E.CCS 21 Unit. -
l l
22 Q
Did any other unit.within @. provide 23 input to these responses?
24 A
There could have been, but I could not say based 25 upon the responses that are provided.
1 LaBelle 222 4
1 2
Q Did you maintain a file with regard to o
i 3
the preparation of responses to these questions?
t 4
A I do not recall.
l 5
Q If there is such a fi,le, where would it
{
6 be?
i 7
A It would be in my. personal TMI-2 chron files.
8 Q
What is meant by the words " initiated 9
normally" which appear in Question--l on Page-1 of 10 GPU Exhibit-288' marked for identification?
11 A
Just what it says, initiated normally.
&fa))
12 Q
How long.after.the loss of main feedwaterg (AFW) 13 would auxiliary feedwater have been initiated g
14 normally?
15 A
I do not know.
16 Q
Was it your conclusion that if auxiliary 17 feedwater had been initiated.normally the pressurizer 18 at TMI-2.would still have fiiled due to HPI 19 actuation on low RC system presuure?
20 A
You are asking if I agree with the response?
21 Q
Is my. characterization of the response g
22 correct?
t 23 THE WITNESS:
Could you repeat the l
[
24 question, please?
i i
25 (The question referred to was read by the h
v
-~,c-
---,----~,-,.,v.
,,--n..-.,---------,,,-n-,---,,,,-,.,,-,p,,,
,,m
,.--,--,wn-r w-,--m,--- - - - - + -
,a n..r---
.e
-,+-wn
I t
1 LaBello 223 9
2 reporter.)
A That is the response that is provided here.
3 4
Q Nas that response based on CADDS i
simulation studies by.the Safety Analysis Unit?
5
]
6 A
Ncit in its entirety, no, sir.
7 Q.
What else was that response based on?
8 A
An extrapolation of the work that was 9
performed with the CADDS code.
i (qveshbn-a) ij 10 Q
Question No. 23 refers to a delay of E
auxiliaryfeedwate(AW) j r at TMI-2.
Do you know what 11 a
j 12 length of delay was being envisioned in this que.s tion ?
i t
I
(? mino6e5) gather that the I would i
13 A
Based on the response,
()
14 time period of eight minutesfwhd ch is consistent with (SCE) j 15 the sequence of eventagfor the TMI-2 incident was l
16 used upon which to provide the response.
i 17 Q
Is it correct to state that based on 18 studies performed by the Safety Analysis Unit you 19 concluded that if the PORV had operated properly at (1905? O
}
20 TMI-2 on March 28th, 1979, there would have been no j
21 core uncovery even though the auxiliary feedwater I
22 was delayed eight minutes?
l l
23 A
That is what the response says, yes.
24 Q
I would like you to refer for a moment
(
25 to Page-2 of GPU Exhibit-488 marked for identification
1 LaBelle 224 i
2 and in particular Question--3 and the response to 4
\\/
Question 3.
3 4
Is it correct to state that the analysis i
5 done by.B ShW indicated that if HPI had not been (190328) i 6
terminated on March 28th, 19794 at TMI-2, HPI would have j
7 been adequate.to prevent core uncovery regardless of 8
a stuck-open PORV and regardless of a delay in (AFN) 9 auxiliary.feedwateg?
10 A
This is what the response says.
The response i
I 11 itself.was not a result that would have been provide.d 12 by.the Safety, Analysis Unit or myself.
13 Q
Who provided this response?
14 A
As best I can recall it would have come from 15 the ECCS Unit..
16 Q
Do you recall who in the ECCS Unit provided 17 that response?
18 A
No, sir.
19 Q
Was it.Bert Duna?
20 A
I do not know, fQ085/7bn(-A) 21 Q
The response to Q.uestion No. 4-A states 4
22 at the beginning:
23 "No.
Raising the bottom of the pressurizer 24 would have made no material difference up through
&0 O,
25 the turning off of the reactor coolant pumps."
g t
n LaBolle 225 i
1 Do you know at what point in time after 2
1Dfl0b
([LN feedwat(erthereactorcoolantpumpsg k
the loss of main j
3 1
were turned off?
4 l
(.5cE)
A Y u are asking do I know the sequence of events 7 5
4
.\\
6 Q
Yes.
i A
At'the time at which the pumps were turned of f ?
7 l
g Q
Yes.
A I cannot recall the exact times, no, sir.
9 10 Q
Do you recall approximately,when that was?
4 II A
The pum s in one loop were turned off around ll 1t j
10$l hob 8Sh 12 seventy. minuteg into the transient and the other loop j
()00-N!lOUb83h 13 around one hundred minutes 4 1nto the transient.
4 s,/
14 Q
Further on in this paragraph there is a i
reference to. a" loop seal effect of our pressurizer 15 16 design."
Can you tell us what is meant by that?
I i
17 A
The loop seal referred to is the fluid within the 1
5 18 surge.line between the coolant loop hot leg and the i
19 Pressurizer inlet.
l 20 Q
How did the loop seal affect come into play t
when steam is present in the primary hot leg and the t
21 f0Ab reliefvalv(egsclosed?
?
i 22 electromatic i
23 A
Are you referring to the period of the TMI-2 l
24 incident?
25 Q
Yes.
4 l
1
}
f a
L
1 LnBolle 226 2
A I could not respond to that because I do not have the expertise to responi to your question.
3 4
Q Who within B{(]khas the expertise to 5
respond to that question?
I 6
A That question was examimed by.the ECCS Unit.
{
7 Q
Do you know who in the ECCS Unit examined
- l 8
that question?
9 A
I know that Mr. Dunn has done some work with 10 respect to the question.
t 11 Q
Can you describe for us the words or the 12 substance of. Instruction-No,-472 referred to on this I
13 page of GPU Exhibit-288 marked for identification?
i (7 s_/
14 A
I have no recollection what the instruction was.
15 g
Was cdditional information ever provided 16 in response to such a'n instruction?
f 17 A
I do not recall.
I 18 Q
.Do you know what additional information 19 is referred to in this sentence?
20 A
No, sir, i
)
g 21 Q
If you wanted to find a copy of Instruction i
9 22 No. 472 where would you look?
23 A
I do not know.
i f
24 Q
How would you ge' about it?
25 A
I do not know who maintained the instructions a
4 4
J
L,
--.a 1
LnBollo 227 2
that were issued.
,~
l 3
\\_/
3 Q
If you wanted to find out who maintained l-4 the instructions that were issued, who would you ask?
5 A
I would have asked my.immediate supervisor.
6 Q
Was that Dr. Womack?
i 7
A Yes, sir.
At that time, at the time of this I
8 memo.
I i
9 Q
If additional information had in fact been 10 provided in response to that instruction, would you 11 have retained a copy of it?
12 A
I do not know.
l 13 Q
Do you know where such additional O,
t,
)
14 information would be found?
x,/
I 15 A
I could only offer a guess as to where it would 16 be.
17 Q
Where would you --
18 A
If it was produced.
19 Q
Where would you look if you wanted to 20 find such information?
}
21 A
If it was produced by the Safety Analysis Unit l
l 1
j 22 it would be in the TMI-2 personal chron file that I 23 maintain.
24 Q
If it was not produced by the Safety 1
, (,
)
25 Analysis Unit where would you look?
I l
1 LaBelle 228 l
N 2
A I do not know.
3 Q
I w uld like you to ref er to Page -2 of 4
GPU Exhibit-2 8 8 and in particular Question--5 and the response thereto.
5 I
6 What was the margin between peak system pressure'after a reactor trip and the set p.oint for 7
(Po&V) 8 the opening of the electromatic relief valvejprior to 9
the TMI-2 accident?
i 10 A
I cannot recall the specific set points for hl?
11 the high pressure 4 trip versus the electromatic relief a
12 valve set point other than to state that the set 13 points were reversed in sequence which is shown here I
)
\\ /'
14 in this response such that the electromatic relief 15 valve set point was put at a higher actuation 16 pressure than the.high press.ure. trip set point of the 17 reactor protection system. -
i 18 Q
Why was this change made?
19 A
The-one consideration that I am aware of was j
i 20 that of attempting to provide protection of the reactor l
l 21 system without actuation of the electromatic relief I
i 22 valve for anticipated operating occurrences.
l 23 Q
Was such a change' ever considered prior to f
24 the TMI-2 accident?
fs
\\
l
\\--
25 A
Not that I am aware of, sir.
a i
f 1
LaBelle 229 2
Q Do you know why it was never O
considered before the TMI-2,secident?
3 4
.A No, sir.
1 5
Q Referring to Question-4 on this same i
6 page, what is meant by,the terminology "electromatic l
fpf )
Y relief.valveAset point drift."?
7 8
'MR.. WISE:
I will permit the witness to answer that question, but I think that you are 9
10 making an assumption about the word " drift" as
}
it is a noun or a verb and I don't j
11 to whether 12 have the slightest idea which it is and I would 13 simply advise Mr. LaBelle that he can explain O-)
14 that term any way he thinks proper.
15 MR..GLAS SMAN :
Well, perhaps at trial we 16 will call in.a grammatician, but in the meantime 17 I guess'we-will have to obtain an answer from 18 Mr. LaBelle.
19 MR. WISE:
I think the word is " grammarian,"
20 but I could be wrong.
21 MR. GLASSMAN: We will call somebody.on 22 that, too.
23 A
I will attenpt to explain what my. understanding 24 would be of the wording of diectromatic relief valve it a no,kn or verb.
25 set point drift, be W
u
1 LaBoJ1e 230 2
The set point itself would remain fixed.
3 However it would be possible to have some' deviation 1;
4
'in'the actual' opening of the valve either earlier il 1
5 han'the set point.value'or later than the set point.
6 value.
7 This would be a random function as dictated 8
by.the nature of the valve and its control system.
9 Q
What is the significance of such set point 10 drift?
11 A
In the context as presented here it would be 90 12 referring to the margin between the high pressure, 1
1
}
13 reactor trip and the acuation of the electromatic
$b (s/
14 relief valv 15 Q
could there be adverse consequences if a 16 reactor trip failed to be achieved after the i
i 17 electromatic relief valve stuck open?
i j
18 A
I think you are attempting to describe a 19 sequence of occurrences which could occur in -- for 20 some scenario.
b 21 Q
Is there any adverse consequence to the l
F 22 system of such a scenario?
t 23 MR. WISE:
Which -scenario?
24 THE WITNESS:
There are many different 25 scenarios that could go along with the opening i
1 LaBelle 231 (poea 2
electromatic relief valvgfand the reactor trip.
O
(,/
3 Q
If the set point for the PORV drifted 4
such that a reactor trip would fail to be achieved i
5 if the valve stuck open, what is the worst possible
' I consequence which you could envision?
o ji 7
MR. WISE:
I object on the grounds it is 8
a hypothetical question.
We have had many 9
arguments over.the course of these depositions 10 about whether or not those questions are proper.
1 11 At this point I will place my objection on the 12 record.
J well, I will permit 13 If the witness
)
14 the witness to answer the question if he can.
15 A
It is very. difficult to discuss consequences 16 without knowing the specific scenario of events.
17 Q
Had you ever considered the possible 18 consequences of a PORV set point drift such that a 19 reactor trip would fail to be achieved if the PORV 20 stuck open before the TMI-2 accident of March 28th, hkO3S8) 21 1979,7 i
22 A
I think you have to put this question into 23 perspec'tive with what we have.been discussing, that 24 prior to and up until the TMI-2 incident it was a
[ ( -)
25 practice to have the reactor trip set point above the s_
t T
E 1
LaBelle 232 hdd 2
set point for the electromatic relief valveAwhich
{/}
is the scenario that you have just referred to.
N-3 4
The purpose of putting the electromatic relief i
valve set point above the reactor -- high pressure 5
l 6
reactor trip set point was to reduce the likelihood 7
that one would have to face that scenario on a more 8
frequent basis.
9 Q
Prior to the TMI-2. accident was there 10 ever any. analysis conducted within BCi]p relating to i
11 set point drift which would result in a reactor trip i
12 failing to be achieved when the PORV stuck open?
ijf 13 A
Not that I am aware of.
)
14 Q
In your response to Question-7, why were 15 the actions.taken co date considered to be short-term 16 actions?
j j
17 A
Because they.were short-term actions.
18 Q
Are the changes in trip and PORV set 19 points which were made after the TMI-2 accident in 1
20 effect for all gD()W designed plants at the present i
21 time?
j 22 A
Could you explain what you mean by.all B & W a
23 designed plants?
i 24 Q
I think the question is self-explantory,
(
25 but I will go on to another question.
1 LaBelle 233 a
2 Are the changes in reactor trip and PORV o
-l set points which were made after the TMI-2 accident 1
3 4
still in.effect at TMI-27 Do you know that?
'I lf 5
MR. WISE:
I will permit him to answer
[
6 although I 'think the question is rather. vague
'l l
_7 and ambiguous given that there may.have been I
8 one set of. changes after the accident and it is I
9 not clear which set you are talking about.
i 10 A
Also, I don't understand what you mean by "still 2
l 11 in effect at TMI-2" since the plant is shut down.
i 12 Q
I will accept your point, Mr. LaBelle.
f 13 Have you considered changes in the set 14 points for the reactor trip And PORV opening back to 15 the original configuration.before the TMI-2 accident?
- o i
16 A
I am not sure I understand your question.
i.
17 Q
Has.R[(]W subsequent to the TMI-2 accident sI 18 recommended that the set point for the PORV be i
l 19 higher than the set point for reactor trip?
k' 20 MR. WISE:
Are you sure that'is the way 21 you want your question?
I 22 MR. GLASSMAN:
What did I do?
l I
23 MR. WISE:
Even Mr. Taylor is shaking his 24 head.
! 0 L
( )
25 MR. GLASSMAN:
Yes.
]
i l
1 LaBolle 234 i
2 THE WITNESS:
Could you read the 3'
question?
i j
4 MR. WISE:
Yes, please repeat the quection, l
5 (The pending question was read by-.the i
(
6 reporter.)
I 7
A To'tha best of my. knowledge, there has been a 8
short-term recommendation provided to operating plants with BCy[$ nuclear steam supply. system (g toas 9
h2V.I 10 alter their-set points for the electromatic relief valvgt and for the reactor protection system high pressurea/N h
l 11
)
12 trip in accordance with the ele tromatic relief valve 1
l 13 having,a higher set point than the high pressure 14 reactor trip set point.
i 15e Q
Is there any consideration currently l
16 being given within n & W to reverting to the prior i
17
' arrang,ement for these set points at which the PORV set f
/
18 point!would be lower than the reactor trip set point?
i i
19' A
It would certainly be of operational interest to l
20 us to.be able to revert back to the previous set
?
21 points.
i 22 Q.
Why would that be of operational interest f
i 23 to you?
I
}
24 A
Because of the capability to accept turbine i
i 25 trips and loa'd rejections with a low frequency,of j
i l
l 5
n
---+--sw.
+-rr--
- - + -,aey-..-7.e-,.,-
-,-vc-c e-
,---w
.p--v
,e,.
- w. w e r e v -er-ww-7ers+i--
--v-
-er-e,,m-
.m=
,,ew-=va-===---ev-we---v---------=r-
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e
1 LaBello 235 L'
i 2
reactor trips during those power run-back situations.
-')
V 3
Q Has there been any. study or analysis made 4
within g[(]W as to how this might be accomplished 5
without calling on the PORV to operate frequently?
6 A
I do not know.
I 7
Q What electromatic manual actions were you 8
referring. to in your response to Question-07 9
A The reference here is to operator instructions h]Sl]
10 for the high pressure injectiongand electromatic manual j
I 11 actions.
I have no recollection of the specific 12 instructions regarding electromatic manual actions.
13 Q
The next sentence in this paragraph V
14 reads as follows:
15 "However, longer term projects for 16 operating plant safety evaluation are necessary 17 and are in preparation by the Safety Analysis 18 Unit."
19 What long-term projects are you referring 20 to?
21 A
I cannot recall specifically what long-term g
22 projects, although the response in the next sentence 23 identifies at least two areas ~ of additional review 24 that were.being performed for the B & W owners group b)
\\
25 and the Nucle'ar Regulatory Commissi
~.
1 LaBelle 236 2
Q Who was performing this additional review?
3 The additional review you are referring to are A
4 the two items listed in the last sentence?
j' 5
Q That is correct.
6 A
Of.Page 4?
r 7
Q Yes.
f L
8 A
These were examined in part by the Safety Analysis 9
Unit.
}
t 10 Q
Did anyone else participate in that work?
i!
11 A
There were others that were involved in these i
12 areas.
13 Q
what o,thers were involved?
O 14 A
I could not specifically identify.the other areas' I
15 involved in that these studies would have cut across 16 the line of responsibilities of many of our engineering 17 staff.
t i
18 Q
Were there any.other longer-term projects i
19 for operating plant safety ovaluation that you now 20 recall?
21 A
Th'ere very.well may have been, but I can just not j
22 recall.
f 23 MR. GLASSMAN:
I'would like to hav's 24 marked as GPU Exhibit-289 for identification a (J;
)
6 90407) 25 five-Page d cument dated 4/7/79 from D.
W.
4 4
I 1
a-1 LaBelle 237 s
2 LaBelle to John Biller.
[)
(e#0 3
(Document dated 4/7/79Ato John Biller 4
from D.
W.
LaBelle, subject:
Request for CRAFT I
(fg$1Ihif--221) ll 5
Analysis," was marked as GPU Exhibit No. 289 4
(globo3)
't-6 for identification as of this datg.)
l 7
BY MR. GLASSMAN:
8 Q
Mr. LaBelle, did you send all or part of 9
GPU Exhibit-Q89 marked for identification to Mr.
4 10 Biller (handing document to the witness).
,I j t 11 A
I must have in that my signature appears on the
{
12 cover memo.
]
13 Q
Do you recognize whose handwriting is i
14 contained on the attachments to the April 7th, 1979 15 cover memo?
16 A
No, sir, I do not.
17 Q
Do you recognize the handwriting at the
^
18 bottom of the cover page?
i 19 A
No, sir.
3-l
- 20 Q
Who is John Biller?
21 A
At the time that this memo would have been 22 issued he would have been an engineer working for Mr.
23 Dunn in the ECCS Unit.
f 24 Q
Should the word loft, 1-o-f-t, tran'sient 25 in the first line of this memortndum properly read s
st n
LODello 238
1 q
, y 4
g 2
1-0-f-W7
(
\\
o\\-
A Y*8' 3
i 4
9 FhY.did you make this request of Mr.
i Biller?
5 l
6 A
According to the memo it was to assess the effect of tripping the~ reactor on turbine trip and 7
g subsequent effect as far as actuation of the' hf.b g
electromatic relief.valveAon the pressurizer.
10 Q
Was not lifting the EMRV1 for'a loss of i
(t,OFW) 11 feedwaterAwith turbine trip desi'rable?
8 I would not\\,1ock at the;1ifting of the 12 A
.s l
13 electromatic relist, valve in tha terms of desirability.
14 I t$1nk this was an'ther study at whether anticipatory o
15.
trips could redued-the. frequency of actuation o'f the 16 electromatic relicC valvo.
,c, s
17 Q
I would'liAe you to refer to-che last page.
,,/, d :,
,i l
18 of GPU Exhibit--2891 marked for identificat. ion.
At th'e
~
s
/=
19 bottom of that page there is a n,ote which reads:
s L
(VlCi k,. LaBu'(lle by N.jK.
/
+
20 "hmo P,as sent to)D. W z{i' l-1979 fat,4:00'p.n!.withthe-21 savsni on Apr 1 9,
f
>\\
ji
\\
\\
22 results of requested computer.'run. ".
, ',s 23 Whocis-N.
K.
!!avanii,
t
}
y 24 A'
<Mr.
Savani at the time the tieno was written;--
U' 25 let me -- please' strikd that.,
N i_
~~a-s
,c,,
1 LaBelle 239 i
2 I-don't know the timing of the note here
(~.-
3 compared with the memo and whether the note may have
'l 3
k )b
,9 4,
been added after the memo was issued to Mr. Biller, I
ig il 5-but that Mr. Savani during this time would have been pg 1.
b M
i
'6 i
- r 6
an engineer working in the ECCS Unit.
f i JI -
7 Q'
Did you receive a memo sent by Mr. Savani l
(790N9) 8 on April 9th, 1979gshowing the results of the
?
j 9
requested computer run?
4-
['IC 10 A
I do not recall.
4 ll 11 Q
If you did, where would it be?
4
%g.
J 12 A
It could be in my personal chron file for TMI-2.
j-t i'i 13 MR. GLASSMAN:
I would like to have marked ll e
{}
(140Wl3) 14' as GPU Exhibit 290 for identification an April l"
15 12th, 1979 memorandum from C.
S.
Banwarth to 3
l 16.l Distribution.
1
=
17 (Memorandum dated April 12th, 1979 to l "~
18 Distribution f-rom C.
S.
Banwarth was marked as 1
)
19 I GPU Exhibit M57-290 for identification as of this date(flobO3) a; l I, f '
20 g) t h
21 BY MR. GLASSMAN:
l F
l-
/,
22 g
Mr. LaBelle, I show you what has been l
. -k
+
23 Marked as GPU Exhibit-290 for identification (handing 7
,f
- r v[,
24
, document to the witness).
p N
~
j
,1- %
Did you receive a copy of that document
/..
/
i F,
C r
. y,, y
. \\ ij ~ W i
.q!.
,.,I t
I-
,. _, -, _. _..,, - ~, -. - - - _ ~
g 1
LaBelle 240 1
in the ordinary course of business?
2 V
A I
ld n t say with assurety that I have.
3 Q
Is there an indication on the document that 4
y u received a carbon copy?
t 5
A What?
i 6
f Q
Is there an indicat.on on the document 7
8 that you received a carbon copy?
A Yes, in the upper right-hand corner of the memo 9
(1904140 10 Of. April 12th, 1979A it shows my name as being on
~
,l 11 distribution or carbon copied.
12 Q
Under the heading " Capabilities" at the (pige-D 13 bottom of the first pageg there is a reference to the Q
i 14 CADDS model being available for evaluating variations f the TMI-2.. incident and in particular whether a i
15 i
16 reactor trip on turbine trip would have resulted in i
17 a significantly different event.
18 Was such analysis ever performed wich 19 the CADDS model for the TMI-2 event?
20 A
I do not know.
21 Q
If you wanted to find out whether such 22 analysis had ever been done, who would you ask?
23 A
If the analysis had been done it would have 24 been done in the Safety Analysis Unit since Mr.
25 Banwarth was associated with the Safety Analysis Unit 4
,.-..-n.,,---
L 1
LnBolle 241 and the-CADDS code is a code that is maintained in 2
(
)
the Safety Analysis Unit.
3 Q
If such an analysis had been done, would 4
there have been a particular calculational file 5
6 relating to it?
7
.A If'an analysis had been performed there would be i
j 8
a calculational file.
l 9
Q At the top of Page-2 there is a reference I
i 10 to the manner in which pressurizer heater operation it would affect progress of the event.
12 Was such an analysis ever done with the 13 CADDS model for the TMI-2 event?
(
)
A I do not know.
i._/'
14 15 Q
If such an analysis had been performed, 16 where would the results of that analysis be found?
l 17 A
If the analysis were performed with the CADDS 18 code, the analysis would be found in the Safety 19 Analysis Unit.
20 MR. GLASSMAN:
I would like to have marked as GPU Exhibit-291 for identification an l
21 l
(OOO4RbD 26th memorandum from D.
W.
LaBelle to E.
A.
l 22 April A
t 23 Womack.
h l
(Memorandum dated April 2,8 th to E.
A.
24 x/
25 Womack from D.
W.
LaBelle, subject:
NRC Meeting l
l l
l t
I
1 LaBelle 242 n Operating 177-Plants, was marked as
/N 2
t (Exhdb-291)
GPU Exhibit No. 291 for identification as of 3
4
$ lobo 3) this date.3) 4
\\
MR. WISE:
I might say that the Xerox 5
i does obscure the last figure in the year on the 6
i I
m einorandum.
However, the first three figures 7
are 1-9-7, and in the course of the memorandum 8
there is clearly,a reference to the accident g
6 90000) which occurred in 1979 10 g
1 4l' gg Consequently, the only year in the
]
(100000) i 12 1970'3 decade that th's memorandure could possibly i
f96YAb) be referring to is presumably April 26th, 197g.
i 13 i
14 MR. GLASSMAN:
I would also point out that I
the second page of the memorandum contains the 15 i
16 notation at the top " April 26th, 1979."
g7 MR. WISE:
That is quite right.
l 18 MR. GLASSMAN:
I think we can stipulate 19 between counsel that the date of this document 20 is April 26th, 1979.
Is that agreeable 7 MR. WISE:
That is agreeable with me.
21 (Document handed to the witness.)
l 22 23 BY MR. GLASSMAN:
24 Q
Mr. LaBelle, I show you what has been 25 marked as GPU Exhibitd91 for identification.
Did you I
1 LaBelle 243 2
send that document to Dr. Womack in-the ordinary 3
course of business?
4 A
I do not recall the memo, but it has my name i
5 attached to it.
i l
6 Q
Does your signature appear on the last lj 7
page of 'this memorandum?
1 l
8 A
The last page is out of place in my copy.
9 MR. WISE:
Let us move on.
This was i
10 signed by,Mr. LaBelle.
Let us go ahead with the l
i i
11 questioning.
12 THE WITNESS:
I would say that I have 13 signed this, counsel.
14 MR. GLASSMAN:
With agreement of counsel, 15 we will reorder the pages.
16 MR. WISE:
It is getting late in the i
17 afternoon.
18 BY,MR. GLASSMAN:
19 Q
Mr. LaBelle, I would like you to review (ZNM*50 2 on Page-2 of this doc ument.
Will you tell 20 Item No.
4 l
21 us, please, sir, whether there was any follow-up with
- l 22 regard to this item by B[hCW7 23 A
I have no recollection of the subsequent history 24 of follow-up on Item 2.
)
25 Q
I would like you to refer to Item 3 on 5
L e-
~
i LaBello 244 i
Page-2 of GPU Exhibit-291 marked for identification O.
which refers to a development of a means to benchmark 3
codes for natural circulation prediction.
Do you know if this was ever done?
i A
I think that this item as well as the other 6
items have to be put into the context that they are 7
j summations of concerns which the Nuclear Regulatory h0]
Commission 4had and were not necessarily concerns which h+ZO)
Wilcox4 ompany.had.
Babcock &
C i
Q Mr. LaBelle, did B & W ever benchmark des for natural circulation?
12
~
A I could not say that there were not some g
benchmark calculations done for certain codes.
Q Do you recall any such benchmark 16 A
Yes, sir.
g Q
What were those?
18 A
I just cannot recall the context in which they gg were conducted or the particular codes involv ed.
Q Has B & W ever investigated by its i
computer codes whether natural circulation could be (4 phase) achieved under two phasegconditions?
g THE WITNESS:
Could you repeat the question, 24 l
P ease?
25 l
l 1
l 1
1 LaBelle 245 l
2 (The pending question was read by the O
3 reporter.)
^'
4 A
There have been' studies conducted by B[q]W of 1
(qqhase) 5 two phase a irculation.
c 6
Q When were such studies conducted?
'I 7
A I do not recall specific tim.es that studies of 8
this nature were conducted.
9 Q
Were studies of this nature conducted (1903M) 10 before the TMI-2 accident of March 28th, 1979g I
l 11 A
There could have been studies conducted within
[l.06A) 12 the loss of coolant accidentAanalysis.
13 Q
Are you talking about the ECCS Unit?
- O 14 A
Yes, sir.
{
15 Q
Are you aware of any studies of this 1
16 nature prior to the TMI-2 accident?
l 17 A
The loss of coolant accident will result in 18 two phase conditions as a part of the transient that
^
19 is examined, but I could not comment as to the 20 nature of the studies conducted.
21 Q
In other words, you do not know whether 22 those studies included consideration of whether 23 natural circulation could be' achieved under two phase 24 conditions; is that correct?
25 A
Since the analyses - -ay awareness of the
~
n
~~,
1 LaBolle 246 4
2 analyses is that adequate core cooling could be pr vided.
There was a form of ciulation that was 3
(a-plase)
't 4
provided for two phasdAconditions.
i The reason I say this is that it is 5
6 necessary,to understand the precise meaning that one 7
might provide to natural circulation in that it is 8
possible to have adequate core cooling and circulation 9
without natural -- what is normally termed natural i
10 circulation.
11 Q
I would like you to refer to Page -3 of 1
12 GPU Exhibit-191 for identification.
At the very
/~T 13 bottom of'.the page there is a statement after the 14 word " basis" that:
15 "NRC has shown concern that (3h]W does 16 not.have benchmarks supporting many of its code 17 Options and capability."
690cs) 18 Is it true that as of April 26th, 1979A i
l 19 B & W did not have benchmarks supporting many of its i
20 code options and capabilities?
21 A
I think that one has to put into perspective g
22 the benchmarks that had been performed with the 23 availability of operating plant information upon which 24 to base-those benchmarks.
l
-")
\\_)
l 25 It.is very rare that one finds a complete set of 4
4 i
c
,n-
-,.-n, n
1 LaBelle 247 2
information pertaining to an operational transient 7_(_)
3 up n which one could benchmark all of the options 4
and capabilities of computer models.
.i 5
Also, the computer models that were in use by l
6 the Safety, Analysis Unit with which I am most familiar 7
were designed to provide conservative results and in 8
many. cases conservative input was used to formulate
\\
g the conservative techniques that were used within the l
}
ic models.
1
}
11 Q
Is it true, then, that even in some j
12 situationswhere.(}(3W had information on the 13 characteristics of actual transients that they were o
(\\
14 not benchmarked?
15 A
We did not benchmark evedy. transient that 16 occurred in that there are many, transients that occur 17 during a given year.
We did have some benchmarks of 18 our -- of the codes that wers us'ed within the Safety 19 Analysis Unit.
20 Q
The next sentence of this paragraph 21 reads:
22 "Thus, we are highly vulnerable to issues 23 such a s those raised in this meeting about 24 analytical credibility when phenomena occuring 25 at our plants have not been previously predicted
L
.,,.s
... ~, _
1 LaBelle 248
()
2 by our codes."
Whag phenomena did you have in mind 3
i 4
which had not.been previously predicted by your codes?
I 5
A I think you have to read the last sentence of
{
i 6
this memo which points out that the codes were --
'(
f
,7 that were being used in the Safety Analysis Unit
.I 8
were designed for conservative bounding Analysis and g
thus it was possible that they.would not reproduce I
10 exactly.or provide best estimate results which could Ii.
5 11 be compared directly,with plant operating transients.
1 j
12 Q
Did any, phenomena.which occurred at in19(410000) even(305) 7A involve a sequence of s not-l 13 Davis-Besse a
14 previously. predicted. by.B{}()W's codes?
t r
15 A
I am not sure I understand the specific events i
16 you are referring to, i
17 Q
I am referring to the events of April
{
(1104A4)
(togn) 18 24th, 1977Ainvolving a loss of coolant accideng.
k-19 MR. WISE:
And what is the question?
20 BY MR. GLASSMAN:
i 21 Q
Had the phenomena which occurred on f
g 670924) 1977 at Davis-Besse been previously 22 September 24th, 4
23 predicted by B & W's codes?
i 24 A
I am not sure of the specific event that you 25 are referring to by date, so I would be unable to A.
L LEOolle 249 1
2 provide a response to what calculations may have been performed concerning ~ that event.
3 4
Q Are you aware of a transient involving (noox) a stuck-open PORV at Davis-Besse in 19777 4
5 6
A I
I have some uncertainty.as to the date.
l 7
8 Q
Was that transient predicted by ([k]W's codes?
g 10 MR. WISE:
Well --
t 11 A
What do you mean by was it predicted by B & W's 12 codes and when was it predicted by B*& W's codes?
13 Q
was it at any time predicted by B & W
(~\\
Jl k
codes in the sense those words are used in GPU 14 15 Exhibit-291 marked for identification?
I am referring i
16 to the last page of the exhibit.
17 A
The event itself that you refer to of a PORV 18 not operating properly wou11 not have been an event 19 that Safety Analysis would have examined in the course 20 of its providing information to the accident
[hAS) 21 analysis of a safety Analysis Reportg
)
22 It very well could be included in a spectrum (Lo&AT 23 of loss of coolant accidentAanalyses performed by l
24 the ECCS Unit.
,/'
i 05 Q
Are you aware of whether it was included F
1 LcBelle 250 2
in any. analysis done by the ECCS Units?
t i
V A
No, sir, I am not.
3 4
MR. GLASSMAN:
Why don't we resume 4
5 tomorrow morning.
6 MR. WISE:
Fine.
7 (Time noted:
5:24 o' clock p.m.)
l l
l 9
l 10 l
11 Subscribed and sworn to i
I 12 before me this-------day 1
f 13 of--------------1981.
' (,-
14 15 16 17 18 19 20 i
21 i
6 l
22 i
i i
23 r
24
!,c \\
n
'L/
25 t
i
w
._~
.6-1 251 CERTIFICATE 1
STATE OF NEW YORK
)
3
- ss.:
i COUNTY OF NEW YORK
)
4
[
I, CHARLES SHAPIRo
, a Notary
' (,-
5
!~
Public of the State of New York, do hereby certify that the continued deposition of 7
DANNY.W. LaBELLE was taken Defore 8
me on June 3rd, 1981
_ consisting i
of pages
'129 through
~30 10 I further certify that the witness had 11 been previously sworn and that the within O
tr===cr1>* 1=
true recora or 1a te=*1=oavi m
That I am not connected by blood or marriage with any of the said parties nor i
15 g
interested directly or indirectly in the matter 16 i
in controversy,,nor am I in the employ of any 17 of the counsel.
l 18 IN WITNESS WHEREOF, I have hereunto set my i
19 4
hand th.ts' l9 day of ' D O NC ~
",IT8/
20 i
i 21 22
)
k CHARLES SHAPIRO, M ;
24 25
I ND E Witness Examination by Page
}
Danny W.
LaBelle resumed Mr. Glassman 131 i
{
E X H I B IT S GPU.. Exhibits For.
Identification 28}
Document headed " Potential Lessons to be Learned from
"' consisting of two TMI-2,h-d) 165 pages 288
- 30th, ggg$$O)Documentd,atedApril l'979fto-Mr. Roy from Mr.
LaBelle, consisting of four pag e s.[(-
65) 217 Geovov) 289 Document dated 4/7/79A to John Biller from D.
W.
LaBelle 237 h00Yl8) 290 Memorandum dated April 12, 1979 3
to Distribution from C.
S.
Banwarth 239 fY90Y$b 291 Memorandum dated April 28$to E.
A.
Womach from D.
W.
Labelle 241
)
.A I
U cl
-